Day 5

Bank St Petersburg v Vitaly Arkhangelsky [Master]

Day 5

Bank St Petersburg v Vitaly Day 5
Arkhangelsky [Master]

1 :1 Wednesday, 3 February 2016
2 (10.30 am)
3 Housekeeping
4 MR JUSTICE HILDYARD: Yes, good morning.

5 MR STROILOV: May it please your Lordship. My Lord, I’m

6 sorry to interrupt the cross-examination, and I hope

7 this matter can be resolved quickly, but I am afraid it

8 is an emergency. I don’t know if you have had a chance

9 to have a look at my e-mail of this morning marked

10 «urgent», which was copied to your clerk?

11 MR JUSTICE HILDYARD: Yes.

12 MR STROILOV: I can set out what we now, quickly,

13 essentially as —

14 MR LORD: Sorry, my Lord —

15 MR JUSTICE HILDYARD: Has this been agreed between you?

16 MR LORD: No, my Lord. I have had almost no notice. This

17 witness is in the witness box. This is all, in my

18 submission, inappropriate. We should finish this

19 witness and then this matter can be raised. I am taking

20 instructions on it, my Lord.

21 MR JUSTICE HILDYARD: Mr Lord, I think that your

22 solicitors — or I hope they were — were sent the same

23 as I was, which is an e-mail of 9.53 am. The reason why

24 it might be appropriate to interpose this is that it may

25 be, if I am to accept what Mr Stroilov tells me — and

2 :1 I have no reason not to at the moment — it may be that
2 something has to be done quite quickly if this is all

3 an error or some misunderstanding, lest the trial be

4 further disturbed.

5 MR LORD: Yes, my Lord. I wonder if, at least

6 this witness — I wonder if the witness could be allowed

7 to —

8 MR JUSTICE HILDYARD: That is a matter for me, Mr Lord.

9 I am saying to you that you must take instructions to

10 resolve this. I am hoping this witness will be over by

11 1.00 pm and that it won’t be too late, but I am anxious,

12 as France is one hour ahead of us, that we should

13 resolve this as quickly as possible.

14 MR LORD: Well, let Mr Stroilov make his application and

15 I will respond to it.

16 MR JUSTICE HILDYARD: I won’t require him formally to do so.

17 You have seen what he says. At some convenient moment,

18 unless there is some particular reason why there is some

19 urgency which can justify interrupting the course of

20 cross-examination, which is unusual, usually

21 unnecessary, and certainly inappropriate unless there is

22 some extreme urgency —

23 MR STROILOV: My Lord, as I understand the position — and

24 obviously you will appreciate it has been — the

25 information was going around at quite a quick pace.

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

3 :1 MR JUSTICE HILDYARD: Yes.
2 MR STROILOV: But my understanding is, if the Bank account

3 remains frozen, there are a lot of payments, literally

4 daily payments are being made by cheques in France.

5 Cheques will be dishonoured, they will be stopped from

6 using cheques in the future.

7 MR JUSTICE HILDYARD: I understand, you have made your

8 point. Mr Lord will have under advisement with those

9 behind him whether this is an error or whether there is

10 some other reason for this, and I will, at the next

11 break, decide when to do it, when I have consulted with

12 Mr Lord as to how his instructions are progressing.

13 MR LORD: My Lord, the instructions are that the Bank

14 doesn’t know anything about this, and the French lawyers

15 for the Bank don’t know anything about this. So nothing

16 has been done to cause this to happen, as far as we are

17 concerned. Nothing has changed in this case.

18 So, my Lord, we are not going to take any steps at

19 all to try to prevent Mr Arkhangelsky coming to Paris.

20 Your Lordship knows that. Therefore we will do whatever

21 is required to resolve it, but if the implication is the

22 Bank has somehow moved, recently, to make things more

23 difficult for him to come to Paris, to this bank

24 account, that is flatly denied. If there is some other

25 wrinkle or problem, we will obviously try to resolve it.

4 :1 As your Lordship knows, we were asked earlier this
2 week whether Mr Arkhangelsky could have a budget of

3 15,000 — I can’t remember, pounds or euros — to cover

4 witness expenses, including his coming to Paris, and we

5 said: could we have a break down please, but in

6 principle, yes. Then the next communication we get it

7 this one.

8 MR JUSTICE HILDYARD: I can’t get into the merits. What

9 I can do is stress the urgency, accept your proposal

10 that this be deferred, if at all possible, to a more

11 convenient moment, but invite your solicitors to

12 double-check, if that is needed, or to discuss the

13 matter with Mr Stroilov at some convenient break, which

14 will be in about an hour and a quarter’s time, in order

15 that I can resolve any issue which is then outstanding.

16 This may all be a misunderstanding. It may possibly be

17 that Mr Arkhangelsky may have misunderstood. I do not

18 know. There is no way that I can get into the

19 substance, but what I can do is try and resolve, or

20 adjudicate, any issue that there may be which might

21 cause a problem, which might have been avoided if we

22 dealt with it sooner.

23 MR LORD: I see that, my Lord, and I will take steps to get

24 any further instruction, but your Lordship will

25 appreciate that if the Bank don’t know anything about

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

5 :1 this, then in the first instance the way this problem
2 has arisen is going to have to be explained by

3 Mr Stroilov so we can see whether there is anything that

4 we can do about it. We are not — I stress, I really

5 stress very, very much that we are moving heaven and

6 earth to make the French taking of evidence effective,

7 and we would do nothing at all to jeopardise that.

8 I want that to be very clearly understood by

9 your Lordship and by the defendants, and if we can

10 assist to iron out wrinkles, we will, of course, do so.

11 MR JUSTICE HILDYARD: Well, Mr Stroilov, I think the best

12 I can do is urge you to get ahead with the

13 cross-examination of this witness, who is, as it were,

14 from your point of view, on borrowed time, because she

15 was expected to leave yesterday, and then to get the

16 clearest possible instructions in order for you to put

17 the most particular explanation of precisely what you

18 say has happened, share it with Mr Lord, and I will then

19 try and deal with it.

20 I appreciate the urgency and, therefore, what you

21 say may have to be recorded later in a witness

22 statement, but whatever is said to me will have to be

23 recorded in a witness statement for the sake of good

24 order, obviously.

25 MR STROILOV: Well, yes, I see, my Lord.

6 :1 Right, I am sorry to have interrupted the
2 cross-examination.

3 MR JUSTICE HILDYARD: That’s all right.

4 Ms Blinova, I’m sorry to have involved you in all

5 that. I hope you had a good evening and I hope that you

6 will be away soon.

7 MS ELENA SERGEYEVNA BLINOVA (Continued)

8 (All questions and answers interpreted except where

9 otherwise indicated)

10 Cross-examination by MR STROILOV (Continued)

11 MR STROILOV: Good morning, Ms Blinova. May I return to

12 a subject you have touched upon briefly yesterday, and

13 I said I would return to it; namely what I might term

14 the philosophy of personal guarantees.

15 As I understand your evidence, you say that while it

16 is normal for any loan to be secured by a pledge and

17 guarantees, isn’t that correct?

18 A. Yes, at this stage.

19 Q. Yes, but the purpose of the personal guarantee is

20 somewhat different from the purpose of the pledge, isn’t

21 it?

22 A. Not quite the case. Both are securing the loan,

23 however, in order to calculate the sum of the necessary

24 collateral, or the necessary security that would cover

25 the loan and the interest, the Bank has a formula to

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

7 :1 calculate that, the necessary cost of the security, so
2 the initial coverage of this security has to be covered

3 by some movable or immovable property or some goods in

4 circulation, ie by various property; and, in addition to

5 that, various pledges could be provided, various

6 guarantees could be provided, both from corporates and

7 individuals. This is the same collateral, the same

8 security, and the Bank has cases, it has practices of,

9 for example, extending a loan solely against

10 a guarantee, so each loan is individual.

11 Q. Yes, but the way I understand — obviously there are

12 exceptions, but as a general rule the purpose of

13 a pledge is essentially to secure the economic interests

14 of the Bank. What I mean is, when giving the loan, the

15 Bank considers if, God forbid, there is a default, there

16 is this real estate or whatever property is pledged, and

17 we can recover our losses. That is the purpose of

18 the pledge, isn’t it?

19 A. As far as I know from practice, should that be necessary

20 to enforce a pledge, the subject to a pledge, the

21 enforcement can be applied against all types of pledge.

22 The actual enforcement is only against a sum of actual

23 overdue debts. Again, I am not a lawyer, I do not take

24 part in court proceedings. However, I know that the

25 Bank is entitled to simultaneously enforce the rights

8 :1 against the pledge and against a guarantee.
2 MR JUSTICE HILDYARD: Mr Stroilov, I don’t wish to interrupt

3 you unduly, but I am conscious of time. Do you dispute

4 and wish to contradict or invite the witness to

5 reconsider any part of paragraph 21 of her witness

6 statement? She has set this out at some detail what her

7 position is, from the point of view of her department,

8 she not being a lawyer, and I think probably one can

9 take it that I know the likely difference between

10 collateral in rem and a personal guarantee.

11 MR STROILOV: I am grateful, my Lord. I do appreciate that

12 I want to take the matter a little further and suggest

13 some inferences from what the witness says.

14 MR JUSTICE HILDYARD: If you can assure me that there is

15 some purpose, but at the moment you are simply asking

16 her to state in different words that which she has

17 already stated, with some care, in paragraph 21, I think

18 it is, of her witness statement, and I can’t — I don’t

19 want repeat evidence.

20 MR STROILOV: Yes, of course, my Lord. Nor do I, really.

21 MR JUSTICE HILDYARD: No.

22 MR STROILOV: So, Mrs Blinova, what I want to put to you is

23 it follows from paragraph 21 of your statement that at

24 the time the loan is given, the Bank obviously hopes

25 that the loan would be repaid. If not, what is

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

9 :1 anticipated is that it would be enforced against the
2 pledge, whereas the possibility of enforcing against the

3 guarantee is seen as highly unlikely; would you agree

4 with that statement?

5 A. No, I would disagree, and I shall repeat: In standard

6 suretyship agreements or guarantees, it is encompassed

7 that enforcements against the provider of the guarantee,

8 the guarantee is dealt with in five or seven days from

9 the day of overdue debts, ie there are no

10 requirements — if I understood your question correctly,

11 sir — there is no requirement to enforce the pledge and

12 not against the guarantee.

13 Q. I’m not suggesting —

14 A. I’m sorry.

15 Q. I’m not suggesting that, Mrs Blinova. I am talking

16 about what you, as a Bank, expect may happen at the time

17 you give the loan. I am not asking you about the legal

18 position. I’m asking you what are the likely scenarios

19 you anticipate at the time you give the loans? I put it

20 to you that the likeliest, and the most desirable thing,

21 is that the loan will be repaid; that is what you hope

22 would happen. Then the second —

23 A. Of course. Of course, the point of issuing the loan is

24 the loan being repayable and a loan term being

25 specified, of course the Bank did hope for the loan to

10 :1 be repaid, as always.
2 Q. Yes. Then second, if that doesn’t work, you expect

3 a second, most likely possibility is that you enforce

4 against the pledge and the recovery is sufficient to

5 repay the loan; is that correct?

6 A. As far as I know, selling the pledge is done at a

7 primary auction. When the pledge is accepted by the

8 Bank, the Bank states a certain value of the pledge in

9 a proper mortgage agreement. However, subsequently the

10 sale is done via an open auction, and whether it will

11 cover the value in full or not, well, the Bank cannot

12 know it at the point of extending the loan. We rely on

13 some valuation of the pledge that is accepted by the

14 Bank, but no more than that.

15 Q. That’s right, but if the value of the pledge, as you

16 understand it, having gone through the appropriate

17 procedures, if it exceeds the value of the loan, then

18 you would expect that it is highly unlikely you will

19 need to actually enforce the personal guarantee, isn’t

20 that so?

21 A. I would like to draw your attention one more time that

22 I have cited standard guarantee agreements. I am not

23 sure what paragraphs I can look at. Perhaps the lawyers

24 would assist.

25 The Bank does not wait for some period of time until

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

11 :1 the actual property pledge would be sold, would be
2 realised, before putting claims against the guarantor.

3 As far as I remember, and interpret correctly the

4 provisions of our agreements, the Bank can do

5 enforcement simultaneously, can enforce all types of

6 collateral, all types of security.

7 I can also add a — I’m sorry, my Lord, if I may,

8 because Mr Stroilov pays a lot of attention to

9 the procedure of realising the pledges, there were

10 situations when I was at the Bank when the guarantors

11 would even pay before, because it takes a while to sell

12 the pledge, it takes some time, it doesn’t take just one

13 day, and here I cannot see a specific sequence of events

14 that would be necessary.

15 Q. I am probably formulating it badly, and I apologise for

16 that, Ms Blinova.

17 What I want to say is, as a Bank, your economic

18 interests are protected by having the pledge. For

19 instance, this is why it is unthinkable for you to

20 accept a pledge without a valuation of that pledge, but

21 it is quite possible, as we discussed yesterday, that

22 you accept a guarantee without any assessment of

23 the financial position of the guarantor; would you agree

24 with that?

25 A. I agree that the Bank can simultaneously accept the

12 :1 pledge with the valuation, and the guarantee without
2 a valuation.

3 Q. Thank you.

4 A. All of it is within the Bank’s internal rules.

5 Q. Yes, and what I am trying to get to is that the function

6 of the guarantees is rather different. You are more

7 interested, in reality, in whether or not a person is

8 prepared to give a guarantee than in guarantees actually

9 being effective; isn’t that so?

10 A. Not quite the case. At the stage of considering

11 an application — again, I am speaking from my personal

12 experience — I do not recall a case when a business

13 owner would refuse to give a guarantee for some personal

14 reasons that — I don’t remember cases when he would

15 categorically deny it and the Bank would say: okay, we

16 won’t demand it. Usually it raises some doubts, some

17 suspicions.

18 There are two things here, there is the

19 psychological side to it with regard to the [guarantee]

20 and, of course, the undoubted financial side to

21 the [guarantee].

22 Q. Thank you.

23 MR JUSTICE HILDYARD: Have we done that?

24 MR STROILOV: Yes, I think I have reached the end of that

25 one.

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

13 :1 MR JUSTICE HILDYARD: Okay, let’s move on.
2 MR STROILOV: I beg your pardon, it takes a little time to

3 find things.

4 MR JUSTICE HILDYARD: That’s all right.

5 MR STROILOV: I would like to ask you about the events of

6 early 2009, essentially late December/early January of

7 2009.

8 Now, as I understand it, you had a lot of work in

9 connection with this client in that period; is that

10 correct?

11 A. Overall this is correct.

12 Q. So you had, especially in January, you had to prepare

13 a lot of documents in connection with the restructuring

14 of the loan, and which were then

15 backdated December 2008.

16 A. Sir, could you please specify what specifically are you

17 asking about, what documents?

18 Q. Well, I am actually looking at paragraphs 76 and 77 of

19 your statement. Perhaps it is easier if I give you

20 references so that you know. {B2/9/13}, {B2/9/36}.

21 A. Yes, I can see these paragraphs.

22 Q. And I understand that you had prepared literally dozens

23 of documents in this short period of time, as quickly as

24 possible.

25 A. As I mention in my statements, at the end of December

14 :1 there was another period when interest became due.
2 I looked at the calendar and 28 December was a Sunday,

3 therefore 29 December was the final day when the

4 borrower could pay the interest, and apart from that,

5 indeed there were many tranches payable under other

6 credit agreements, and this is what I am describing

7 here.

8 I also refer to the meeting between Mr Savelyev,

9 Mr Arkhangelsky and Mrs Mironova, and then based on the

10 meeting results I was asked to prepare the necessary

11 documents with regard to drawing up the agreements, the

12 understandings reached at the meeting, and I started

13 doing some of this work in December, and having agreed

14 that with the management, I was allowed to carry on

15 after the long new year’s holiday.

16 That’s it, that’s the way it was.

17 Q. Yes, Mrs Blinova, it is with no disrespect and your

18 evidence is obviously very valuable, but sometimes it’s

19 not necessary, really, to tell again what you have told,

20 you can just say yes. That is absolutely normal if

21 there is nothing in substance you wish to …

22 A. Sure.

23 Q. Just to be sure I understand the sequence correctly, so

24 following the meeting between Mr Arkhangelsky and

25 Mr Savelyev, the first thing that happened is actually

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Arkhangelsky [Master]

15 :1 that on the computer system the terms of the relevant
2 agreements were changed, so first came the computers,

3 rather than formalising the papers; is that right?

4 A. Initially after the meeting, that happened at the end

5 of December, as far as I know.

6 Mrs Mironova told myself, the credit department and

7 another employee, who was also involved in working with

8 this group of clients, she informed us that there was

9 an understanding that the client will be granted

10 a relief and the payment can be made on 29 December of

11 the next year.

12 MR JUSTICE HILDYARD: Ms Blinova, to assist you, the

13 question was: was the first thing that had to be done to

14 enter a computer entry or to formalise some papers?

15 A. Yes, my Lord.

16 MR JUSTICE HILDYARD: So try and focus on the question

17 because that way you will get back earlier. If you feel

18 you need to explain, do let me know, but for the moment,

19 the question is: computer first, or paperwork first;

20 which is it?

21 A. My apologies, my Lord. I shall endeavour to be more

22 laconic.

23 Initially there was the computer system. It was

24 necessary to close the so-called balance. We could not

25 delay that, otherwise these sums would be automatically

16 :1 labelled as overdue loans, yes.
2 MR JUSTICE HILDYARD: Thank you.

3 A. The first thing we did, we made changes in the computer

4 system.

5 MR STROILOV: The next thing — as far as paperwork is

6 concerned, I understand that the next thing that

7 happened, you prepared the actual contractual documents,

8 the additional agreements; is that right? As opposed to

9 internal documents such as approvalship; is that

10 correct?

11 A. Unfortunately I do not recall everything in such detail

12 now, but having looked at the documents provided to me

13 when I was preparing, I can see that on 31 December

14 I sent a long list of approvals of the minor credit

15 committee of Investrbank branch to my manager,

16 Ms Borisova, and the way I understand it, initially

17 I did specifically the internal approvals documentation.

18 That would have been logical.

19 Q. Thank you. Yes, then the purpose of backdating these

20 documents to December, as I understand it, was because

21 these documents need to be shown to the banking

22 regulator, and you need to keep the chronology in order;

23 was that the reason why they had to be backdated

24 to December?

25 A. Well, because changes had been made in the software,

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

17 :1 as of December, obviously the document had to be
2 backdated to December.

3 Q. And the reason why you had to do the changes in December

4 was because otherwise the computer system would write

5 the money off automatically, you have said.

6 A. Yes, the amounts would have fallen in arrears, and

7 obviously if there was some positive balance on the

8 accounts that would have been written off, but the rest

9 of it would fall in arrears. There is no way one can do

10 anything about it unless those arrangements have been

11 achieved and those additional agreements had been

12 entered into.

13 Q. Right, Mrs Blinova.

14 So this work, as I understand it, was done by you,

15 Mrs Yashkina, and is that it, or were there any other

16 people involved in preparing these documents?

17 A. So far as I can recall, that was a routine kind of work,

18 so the credit officer was in charge of this, it was then

19 supervised by the head of — by the boss, by the

20 supervisor, and the lawyer. I do not believe that we

21 involved anyone else, really. Obviously then this all

22 went to the client for his final sign-off.

23 Q. Mrs Blinova, it seems — and I don’t necessarily intend

24 this in a critical way, but as a matter of fact it seems

25 that within Bank of St Petersburg the reality is often

18 :1 quite different with what we see on the documents, isn’t
2 it? By that I mean agreements made in January are

3 backdated to December, minutes of meetings which took

4 place one day are dated another day, there are

5 declarations — the Bank certifies, Bank employees such

6 as you, certify that signature was made in your presence

7 whereas it wasn’t, and then sometimes, as we’ve

8 discussed yesterday, large files are being substituted

9 in their entirety just because your bosses have said so.

10 But I just put to you this fact.

11 A. Well, you have asked a very lengthy question, sir. Now,

12 so far as client work is concerned, the way I see it,

13 this is part and parcel of what the Bank does. The Bank

14 does have rules and regulations. It is then supervised

15 by the Central Bank of the Russian Federation, but then,

16 of course, there are ways we can help our clients if we

17 need to.

18 Now, so far as backdating documents is concerned,

19 these documents — again, the way I see it — it was all

20 done for the benefit of the client.

21 Now, had the client refused to sign this in January,

22 then I would have thought that those amounts would fall

23 in arrears, I mean if there had been a refusal to sign

24 those documents. So I do not believe that there is

25 a major breach, really.

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

19 :1 I think there is a balance between the interests of
2 the Bank and the interests of the client.

3 Q. Yes. So, so long as you don’t feel it has prejudiced

4 the client and so long as your bosses are happy with it,

5 you don’t really feel you are doing anything wrong?

6 A. Do you mean myself, personally?

7 Q. Yes.

8 A. Well, in my personal capacity as an employee of

9 the Bank, I believe that the matter has been agreed upon

10 by the authorised body of the Bank, and there is

11 an agreement between the Bank and the client. I do not

12 believe that I am in breach. I don’t think that I am in

13 any material breach of any rules or regulations.

14 Q. And I want to make it clear that I am not alleging that

15 you, personally, are. Now, Mrs Blinova, at any time in

16 the period of frantic work in January 2009, did anyone

17 suggest to you that even if the personal guarantee for

18 one loan or another hasn’t been put in place by mistake,

19 now is the time to correct the mistake and the personal

20 guarantee must be in place?

21 A. I’m not sure I understand your question. My apologies.

22 What is it, exactly, that you mean? What period of time

23 are we referring to? Could you be more specific with

24 respect to the time frame, please? What is it exactly

25 that had to be signed off on?

20 :1 My Lord, could I have the question put in a more
2 specific form, if I may?

3 Q. I mean as part of your preparing the restructuring

4 paperwork, you have to prepare a lot of documents. Was

5 it suggested to you by anyone in that period that if any

6 personal guarantees are missing, they must be put in

7 place now? I am talking about this restructuring

8 paperwork.

9 A. Well, of course not.

10 Now, if you are referring to the suretyship or

11 guarantee contracts, the guarantee contracts, at least

12 with respect to those loans, were entered into at the

13 time of the signing of the loan agreement. There is

14 a provision in the loan agreement making reference to

15 that, and I believe that the dates are the same as the

16 ones in the loan agreement.

17 In January we were only working on the addenda, the

18 additional agreements to the already existing

19 agreements.

20 Q. Mrs Blinova, do you recall at any time between then and

21 now being told that you mustn’t destroy or discard any

22 paper documents or electronic documents relevant to this

23 client?

24 A. No. No.

25 Q. Now, Mrs Blinova, I think actually I won’t be long now.

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

21 :1 There are just a couple of things.
2 If we could have on the screen {D40/691/1} on one

3 screen, and {D40/691/2} on the other.

4 I think I have something called «monitor status» on

5 that screen, so if that could be removed somehow.

6 Ms Blinova, just another question —

7 MR JUSTICE HILDYARD: The same goes for me, actually, so

8 I can’t really read it. Shall we just pause while that

9 is removed, because I can only read two-thirds of it.

10 MR STROILOV: And I think that it is important, maybe, to

11 look at two documents here. (Pause).

12 Has your Lordship’s been …

13 MR JUSTICE HILDYARD: No, but I think he is doing the

14 rounds. (Pause)

15 MR STROILOV: So, my Lord, is everyone happy with what we

16 see on the screen? Is that satisfactory, technically?

17 Really the only thing I meant to ask Mrs Blinova is,

18 I think, again the English version says «signature

19 illegible». Can you confirm this is, in fact, your

20 signature, what you see in the Russian version?

21 A. So far as I can see, yes, I think it is my signature.

22 It’s partially erased, but I think it does say

23 «Blinova». It’s not a very good copy, I am afraid.

24 Q. Thank you.

25 A. To be honest, I can hardly read this, but it does look

22 :1 like my signature.
2 Q. I am not sure, perhaps if you have a hard copy anywhere

3 near you, perhaps someone might help you to find that.

4 So that’s …

5 A. I can see the hard copy, I have it in front of me, but

6 unfortunately this is not a very good copy at all.

7 Q. Now, if you could have on one screen {D41/737/1}, and on

8 another, the same tab, {D41/737/2}.

9 Again, Mrs Blinova, it is the same question: that

10 the signature translated as illegible, is that actually

11 your signature?

12 A. Again, the same answer. Even though this is a bad copy,

13 I think this signature does look like my signature, but

14 it’s not a very good copy. It’s not very clear.

15 Q. Yes, then if I understand your evidence correctly,

16 I think even though, strictly speaking, you have

17 certified something that is untrue, again, your approach

18 is you have done nothing wrong because it is for

19 everybody’s good and because your bosses have told you

20 it is all right; is that the gist of your approach to

21 that?

22 A. Once again, please? I’m sorry, I was distracted, I was

23 looking at the document.

24 Q. I just want to inquire very briefly. I understand that,

25 as you said, you don’t feel you have done anything wrong

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Arkhangelsky [Master]

23 :1 by signing this certification, and I’m just checking
2 I understand you correctly. The reason you have signed

3 to something that is not strictly true, you said you

4 have witnessed the signature; in fact you haven’t

5 witnessed the signature.

6 A. What I was saying, and I think we discussed that

7 yesterday, was that with respect to

8 Julia Arkhangelskaya, sometimes we allowed her to sign

9 documents outside of the Bank whereupon the Bank had to

10 receive the properly executed copies.

11 Q. And so you don’t feel that you did anything wrong for

12 two reasons, as I understand it: firstly, it did no harm

13 to anyone innocent, like Mrs Arkhangelskaya, in your

14 opinion, and, secondly, because your bosses told you

15 it’s all right to cut this particular corner and to be

16 not too strict about this; is that so?

17 A. Well, I recall that at that time Mr Arkhangelsky was

18 breathing down our necks, really. He was trying to

19 accelerate the process. I kept receiving calls and

20 questions from my bosses and asking me when the loan was

21 going to be extended. I got calls from him, from his

22 employees, and he was worried, and I think I have

23 mentioned that I kept talking to people from the finance

24 department of Oslo Marine. Almost every day started

25 with a telephone call where they would ask me: where do

24 :1 we stand? So he had a vested interest in making sure
2 that the loan was disbursed as soon as possible and

3 obviously the documents were processed on an accelerated

4 basis in his interest.

5 Q. So what I suggest to you, Mrs Blinova, is that, rightly

6 or wrongly — I am not trying to criticise you — but

7 when you are under pressure from your bosses or from

8 an important client, whatever, you are prepared to sign

9 a document stating that you have witnessed a signature

10 which you, in fact, haven’t witnessed; do you accept

11 that?

12 A. I think I already discussed that in my witness statement

13 and I really do not want to rehash this.

14 Q. But what I am putting to you, Mrs Blinova, is that your

15 witness statement is another document where you are

16 confirming that you have witnessed something which you

17 haven’t witnessed, simply because your bosses have told

18 you to do so.

19 A. What is it exactly that you are referring to when you

20 are saying I was «witnessing something»? I’m not sure

21 I understand your question. I think I have provided

22 exhaustive explanation yesterday, speaking from memory,

23 when we discussed the signing of the various contracts.

24 Q. Yes, Mrs Blinova, I am not talking about that. I am

25 putting it to you that your witness statement is false

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25 :1 evidence to which you signed under pressure from your
2 bosses.

3 MR JUSTICE HILDYARD: All of it? Which bits of it?

4 MR STROILOV: I think I have identified bits, but I am now

5 going to the reasons why I suggest this witness is not

6 telling the truth, my Lord.

7 MR JUSTICE HILDYARD: The way the question is framed, you

8 are putting to this witness that every bit and bob of

9 her witness statement is false, and it is false because

10 she was told to make a false statement. That’s a pretty

11 broad allegation, for which there is no basis. A lot of

12 this witness statement is not challenged by you: how can

13 you put that question in such broad terms?

14 MR STROILOV: Well, my Lord, because I would submit that the

15 spousal consent declarations suggest pretty strongly

16 that the approach of this witness is such as I have put

17 to her.

18 MR JUSTICE HILDYARD: Well, the position as I understand

19 it — I don’t wish to interrupt too much — the position

20 this witness adopts on the spousal confirmation was

21 fairly exhaustively examined in questions and answers

22 yesterday and, in a nutshell, she accepts, as I think

23 I summarised yesterday, that on occasions, possibly on

24 most occasions, and to suit their busy lives,

25 Mrs Arkhangelskaya did not attend to sign the personal

26 :1 spousal consent, but was given the documents and they
2 were returned, and her signature was matched with the

3 signatures that they had at the Bank for her.

4 It is true that the certificate did state that she

5 was in her presence and this witness has acknowledged,

6 I think, that it was incorrect so to state. But it was

7 to suit Mrs Arkhangelskaya, it was in accordance with

8 what she had been told by the people you call her

9 bosses, and no substantive harm was done. That’s what

10 her evidence is.

11 Now, I’m not sure she says otherwise in her witness

12 statement, she is rather maybe more, as she would put

13 it, laconic on this, but we have explored it.

14 MR STROILOV: Yes, we have, I’m trying to draw an inference.

15 MR JUSTICE HILDYARD: An inference of what? That because of

16 this she is a liar; is that what you are saying?

17 MR STROILOV: Well, yes. I am saying —

18 MR JUSTICE HILDYARD: She is a liar and she has told a whole

19 series of lies, such that her entire witness statement

20 is unreliable, to please her bosses. That’s so

21 extravagant, Mr Stroilov, it’s also something which, if

22 I were a witness, I would object to extremely strongly.

23 MR STROILOV: Well, obviously we need to see if Mrs Blinova

24 objects.

25 MR JUSTICE HILDYARD: It is obvious that…

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27 :1 Mrs Blinova, is your entire witness statement a pack
2 of lies which you were told to tell by your bosses? The

3 entirety of it?

4 A. Well, for my part, can I say that the witness statement

5 was written on the basis of my personal recollections of

6 what had happened at that time, to the extent that I was

7 able to recollect that, and so what I was able to

8 recollect I did write down; what I was not able to

9 recollect, I did not write down.

10 So there were certain things that I could recollect,

11 and I put that into my witness statement and I really

12 have nothing to add to that.

13 MR JUSTICE HILDYARD: Right. Now Mr Stroilov, if you have

14 points within her witness statement which you say are

15 untrue and which you wish me to infer were put there

16 because Ms Blinova was under pressure from her bosses,

17 you must identify them and you must put them to her.

18 You have done the spousal consent.

19 MR STROILOV: Yes.

20 I put it to you, Mrs Blinova, that, in fact,

21 Mr Arkhangelsky has never signed any personal guarantees

22 given to your Bank.

23 A. Well, I beg to differ. I disagree with your statement.

24 Q. I further suggest to you that, in fact, the so-called

25 personal guarantees were fabricated in January 2009 at

28 :1 the time there was a restructuring of OMG indebtedness,
2 and backdated.

3 A. Again, I strongly take issue with what Mr Stroilov is

4 saying. Once again, I would like to point out that the

5 guarantees were reflected in the decisions made by the

6 Bank with respect to every single loan. Without that,

7 there is no way we would have extended a loan unless

8 those contracts had been entered into. I’m trying to

9 describe to his Lordship the standard practice of

10 the Bank. At the time the loan is extended, the loan

11 administration department looks into the proposed loan,

12 if some documents are missing there is no way the loan

13 will ever be disbursed, we will not be allowed to

14 disburse the loan. Therefore, once again, I do recall

15 very clearly — and I’m absolutely certain that those

16 documents, those contracts, were actually executed as of

17 the date which appears on the relevant document.

18 MR LORD: My Lord, if it is going to be suggested that this

19 witness fabricated documents, then it should be put to

20 this witness, as opposed to just in the — whatever the

21 voice is that was used then.

22 MR JUSTICE HILDYARD: Ms Blinova, were you ever asked to

23 backdate any personal guarantee which you understood to

24 be being given by Mr Arkhangelsky?

25 A. No, my Lord. I have never received instructions to that

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Arkhangelsky [Master]

29 :1 effect from anyone.

2 MR JUSTICE HILDYARD: Were you ever asked to insert a copy,
3 or the original of a personal guarantee, in a file in

4 such a way as to give the impression that it had been

5 signed on an earlier date when you knew it had not been?

6 Were you ever asked to do that?

7 A. No. No one had ever asked me to add any documents that

8 would create the impression that they had been entered

9 into at a backdate.

10 MR JUSTICE HILDYARD: Did you, or did anyone suggest to you,

11 that in the hurry, the signature of a personal guarantee

12 had been omitted and that something would have to be

13 done to remedy that error in a way which would not

14 thereafter appear from the way the document was

15 presented?

16 A. No. If certain mistakes or typos were made in

17 the documentation — and this is something that the loan

18 administration department would have looked into — we

19 would have asked the client to re-execute the document.

20 Only the client.

21 MR JUSTICE HILDYARD: Have you been given any instructions

22 by anyone else within the Bank to suggest to this court

23 that a document which you didn’t know was authentic, you

24 should nevertheless claim was authentic?

25 A. No. No one has ever issued instructions to that effect,

30 :1 and I have always believed, and I still believe, that
2 all those documents are authentic.

3 MR JUSTICE HILDYARD: Do you want to add anything?

4 MR STROILOV: I’m grateful, my Lord. I think just a couple

5 of things.

6 MR JUSTICE HILDYARD: Yes.

7 MR STROILOV: I want to ask you about the events after the

8 alleged default, or series of defaults under different

9 OMG loans. You say you sent notices of demand to

10 the corporate borrowers, and you sent them by registered

11 mail with recorded delivery, and let me translate it

12 into Russian, because there was confusion between the

13 banking experts in terminology. What I mean, zakaznym

14 pis’mom suvedomleniyem; is that so?

15 A. Yes. When a loan fell in arrears, a notice was prepared

16 and it was sent. Mind you, I may not have written this

17 very clearly. I personally, obviously, did not go to

18 the Post Office at that time. We had an assistant, we

19 had a secretary who was in charge of that, so she was in

20 charge of actually sending correspondence to

21 the respective addresses, to the respective companies

22 that I asked her to send the correspondence to.

23 Q. And then —

24 A. My apologies, can I just add something? I think it is

25 quite important. Now, apart from the documents being

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Arkhangelsky [Master]

31 :1 sent by registered mail, we also used e-mails. We
2 always sent e-mails, faxes, or got on the phone and

3 spoke with clients, or sometimes we even spoke

4 personally — for instance, I remember once saying this

5 to Mr Berezin in a personal, face-to-face meeting.

6 Q. But I understand that none of these e-mails survived to

7 be disclosed in these proceedings; is that correct?

8 A. What I can say is that when I was preparing to give

9 evidence, I found a reference to a letter that I had

10 sent to Oslo Marine Group. I think it was dated

11 1 April, if I am not mistaken. Yes, 1 April, and this

12 is something that I discuss in paragraph 98, and at the

13 end of paragraph 98 of my witness statement, I do say

14 that I notified Mr Arkhangelsky, as the director of

15 Scandinavia Insurance, and as the guarantor, that some

16 loans had fallen into arrears.

17 Q. Can you clarify a little more how, exactly, your e-mails

18 from that period were preserved or not preserved so as

19 to survive until 2012 and after.

20 A. Well, again, I explained a bit in my evidence, in my

21 written witness statement, in principle I never made it

22 a task for myself to save all the mail that I sent to

23 clients. We have many clients, and a vast volume of

24 information to be sent. Quite often if something has

25 been finished, I would have deleted the letters myself.

32 :1 I was following the recommendation of our IT department
2 because it is a large volume of mail and the resource,

3 the server was getting very slow and it doesn’t work

4 properly.

5 Then when I left on my first maternity leave in

6 2011, I was also recommended to clean up my mail as much

7 as possible, because it was needed to archive things and

8 because my workstation came up free, that should have

9 been assigned to another employee that would be

10 replacing me. Maybe I am not using the correct terms,

11 but at that point in time I didn’t really seriously give

12 it some thought whether to delete something or not.

13 I deleted some letters, and some letters might have been

14 deleted in the archiving process. I don’t know any more

15 on the subject.

16 Q. So, turning back to the notices, I understand that

17 notices under personal guarantees were posted

18 separately, weren’t they?

19 A. Naturally I was sending notices to the borrower, if

20 necessary, to the creditor and to the guarantor; to all

21 the people, yes.

22 Q. Would they be done at the same time as the notice to

23 the corporate borrower and to the guarantors?

24 A. I cannot recall exactly with regard to the dates because

25 I do not recall, according to the agreement conditions,

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Arkhangelsky [Master]

33 :1 whether we should have issued such demands straightaway
2 or after some time, and sent them to the guarantors.

3 Also some time could have elapsed to sign these

4 documents. I don’t know whether our employee was

5 visiting the Post Office on a daily basis. I wouldn’t

6 be able to say exactly.

7 Q. But, presumably, that employee goes to the Post Office

8 with a very large bunch of letters to send and sends

9 them in one go. Is that how that works?

10 A. I did not track the work of that employee. I don’t know

11 her work schedule, whether she did it once a day,

12 several times a day or every other day. At that point

13 in time I wasn’t concerned with that very much. I was

14 sending these letters, and subsequently I would either

15 receive a notification that the letter was delivered

16 safely, or the actual letter would come back if it

17 didn’t work out to deliver the letter, then I would send

18 the letter again.

19 So using all available methods, we endeavoured to

20 notify a client, and all these matters, it’s something

21 I remember very well, because within the Russian

22 proceedings the Bank’s lawyers always asked me to

23 provide a confirmation that I did my utmost to notify

24 the client, and also we had to attach the postal slips.

25 Q. Yes. But in these proceedings, whereas we had quite

34 :1 orderly disclosure of the proof of delivery of notices
2 to corporate borrowers by the zakaznym pis’mom

3 suvedomleniyem, registered mail with recorded delivery;

4 however, the position in relation to the alleged

5 guarantors is much more confusing. Initially we were

6 not given any proof of postage or delivery. When we

7 pressed the lawyers, we were given some tables which

8 purport to be proof of postage, but it appears it wasn’t

9 sent by registered mail with recorded delivery, by which

10 I mean using the Russian postal terms, zakaznym pis’mom

11 suvedomleniyem; why is that?

12 A. I do not recall at this point in time because there were

13 many letters. I think, within my preparation to

14 the proceedings, I saw one of the letters, or rather one

15 of the standard delivery notifications, sent to

16 Kharkovskaya Street address. I recall, and you are

17 correct, sir, most of the letters would come back, of

18 the letters that I sent directly to Mr Arkhangelsky, and

19 I was looking up all possible addresses. Also the Bank

20 somehow knew the Kharkovskaya Street address, and one of

21 the notifications, which is something that I remember

22 very clearly, when I was getting prepared for the

23 proceedings, that letter was delivered. When letters

24 did get back, I saw no point to send each notification

25 by a specific letter. I would gather them up and send

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Arkhangelsky [Master]

35 :1 three or four notifications.
2 Moreover, I also would sent notifications via

3 e-mail. I did my utmost in order to notify

4 Mr Arkhangelsky.

5 Q. But Mr Arkhangelsky would be visiting Investrbank office

6 regularly between March and July, and I put it to you

7 that no one ever gave him accord of the notice or told

8 him that he was in default and must pay; isn’t that

9 correct?

10 A. No, this is not correct, and your question made me

11 recollect something. You are right, sir, indeed

12 Mr Arkhangelsky visited the Bank very often during that

13 time period in March, in early April, and once

14 I actually had some notifications that came back signed.

15 I do not recall the exact loan that they pertained to.

16 Mr Arkhangelsky was passing by, and I said to him:

17 Mr Arkhangelsky, would you please take the letters,

18 these are for you, and he did this gesture (indicates)

19 and said: please send them by mail, please post them.

20 So he refused taking them from me directly.

21 Q. Now, while we are on this subject, I think it has been

22 suggested, Ms Blinova, that in April, certain people

23 were trying to contact Mr Arkhangelsky on behalf of

24 the Bank to negotiate some amicable solution to the

25 dispute which arose. Do you know of any such request

36 :1 coming to Investrbank to try and arrange some meetings
2 with Mr Arkhangelsky to negotiate the general dispute

3 which arose in that period. Does that …

4 A. No. I do not recall anything like that. I don’t know.

5 Q. And, according to your recollection, Mr Arkhangelsky

6 continued to visit Investrbank throughout March, April,

7 you said; what about May? Was he still visiting in May?

8 A. I do not recall exactly month by month, but I recall

9 that the overdue debt started accruing from round about

10 the start of March, and in April. I do not recall

11 about May. They are too close together, these months.

12 I remember that he was visiting the Bank regularly and

13 he could have called someone on the phone, one of

14 the managers, or write e-mails. But he did appear at

15 the Bank.

16 Q. Yes, but what about — I think you have answered that,

17 you don’t remember. Just to be sure, what about June?

18 Did it go as far as summer? Do you recall him

19 contacting Investrbank in the summer as well?

20 A. I do not recall exactly, because so much time has gone

21 by. I do not recall the exact month. That would have

22 been incorrect to surmise or to speculate. I simply do

23 not recall. I remember that in spring, as I said,

24 in March or April, that was happening on quite an active

25 basis; and then I don’t recall.

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Arkhangelsky [Master]

37 :1 Q. Right. Sorry to jump from subject to subject a little.
2 About these notices, do I understand correctly that you,

3 on these notices, you actually put the address which was

4 given to you by someone else? I am talking about

5 notices under the personal guarantees. So you were

6 simply given the address and you put it on those?

7 A. No. No one could have given his address to me. I would

8 directly look up the guarantee agreement and I would

9 then use the information and I would look up the address

10 stated in the personal guarantee, and lately, I would

11 add the other addresses known to me. I do not recall

12 who told me that.

13 Q. Yes. Well, I put it to you that Mr Arkhangelsky, in

14 fact, never received any of these notices.

15 A. Sir, I wouldn’t be able to say anything in this regard.

16 I could only reiterate that I did send them properly and

17 duly.

18 Q. Right. Now, something I want to put to you is that in

19 the Bank’s documents, one of which we looked at briefly

20 yesterday, but in the Bank’s internal documents, we very

21 often see suggestions, recommendations or decisions to

22 advance a loan secured by guarantees, or to advance

23 a personal loan without investigating the financial

24 position of the guarantor, or in some cases the

25 borrower, without, in the case of personal guarantor,

38 :1 without asking for life insurance, and certainly without
2 making the direct debit agreements with other banks.

3 So what I am suggesting to you is that this is

4 a veiled decision, or proposal, to put, to record that

5 the guarantees are there in the Bank’s internal

6 documents without actually going through the trouble of

7 arranging the guarantees. Would you accept that

8 proposition?

9 A. To be honest, I do not understand what the question was,

10 sir. Overall, your assertion, sir, was very lengthy.

11 Would you, perhaps, be able to split it into segments?

12 Q. Let me, perhaps, look at the document we looked at

13 yesterday first, so that you just recall. I do

14 apologise, I am probably putting things very

15 imperfectly. (Pause).

16 Sorry about that, my Lord.

17 MR JUSTICE HILDYARD: It’s all right.

18 MR STROILOV: I am just lost in the documents.

19 MR JUSTICE HILDYARD: It’s all right. (Pause).

20 Would you like a break at this moment?

21 MR STROILOV: I do think so, and I think I will actually

22 finish sooner than when your Lordship indicated. If

23 I have a 15-minute break now, I expect to be finished,

24 as far as I’m concerned, by 12.30 pm.

25 MR JUSTICE HILDYARD: Very well. 15-minute break. Thank

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Arkhangelsky [Master]

39 :1 you.
2 (11.45 am)
3 (A short break)
4 (12.02 pm)

5 MR STROILOV: May it please your Lordship.

6 Mrs Blinova, you can see on the screen, I think it

7 has been called on the screen, the documents, I think

8 for the transcript, documents {D1/2/9} and {D1/2/19},

9 that is the Russian version and the English version of

10 the document we looked at yesterday. That’s your

11 report, as the loan officer on the proposal for

12 Vyborg Shipping credit line.

13 We looked, you will recall, at section IX at the

14 bottom of that page, where there is a recommendation to

15 advance the loan, and the security for the loan being

16 a pledge, and then the guarantees, but without doing any

17 life insurance, without investigating the financial

18 position of the guarantors, and without tripartite

19 direct debit agreement.

20 What I am suggesting is that this amount, in this

21 document, and in many other internal documents of

22 the Bank, this kind of recommendation amounts to

23 a proposal to record the guarantees as being in place

24 without actually obtaining the guarantees.

25 A. A guarantee is entered into by executing a relevant

40 :1 document. Now, what you have just been referring to
2 with respect to the tripartite contracts for financial

3 the conditions and so on and so forth, are so many

4 details. The Bank has certain regulations. This

5 security was part of the regulations. Entering into

6 a guarantee contract is one thing, whereas addenda to

7 that contract is a separate and totally distinct matter.

8 Q. Yes, but what I mean is that what is suggested in this

9 document, and in many other documents where similar

10 wording is used, what is suggested here is that you

11 write in your internal documents that there is

12 a guarantee in place, but in fact you don’t bother to

13 enter into a formal contract of guarantee, or to

14 contextualise it.

15 A. Well, I believe that from what we see here on the

16 screen, it doesn’t say that there is a formal or

17 otherwise contract. There is a guarantee provided by

18 Vitaly Arkhangelsky, and then there are certain terms

19 and conditions that the Bank will not look into this,

20 but there is nothing stopping the Bank, if need be, to

21 ask the guarantor to provide some additional documents.

22 This is part of the contract.

23 If, at some point in time, the Bank decides that it

24 needs to look into the financial condition of the

25 guarantor, it is free to do that. This in no way

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Arkhangelsky [Master]

41 :1 affects the entering into the guarantee contract.
2 That’s just one of the terms and conditions.

3 Or, rather, not even a term and condition, it is

4 just an internal — how shall I put it — an internal

5 regulation, internal guidelines on the part of the Bank.

6 Q. I’m sorry, I probably formulated it badly. What I am

7 saying is that this kind of proposal doesn’t mean just

8 what it says. It is, in fact, a veiled proposal to

9 record in your internal accounting documents, in reports

10 to Central Bank, and in whatever documents, that there

11 is a guarantee, but not to bother to put an actual

12 guarantee in place, or to ask him to sign. Isn’t that

13 so?

14 A. No. It is not so. This is not the case, Mr Stroilov,

15 and I strongly disagree with this. You totally

16 misconstrue this. You are going by my conclusions, and

17 the main conclusion was something that was decided by

18 the management board of the Bank, which sets out the

19 terms and conditions and the main parameters of

20 the loan, and if there is a guarantee requirement there,

21 then the guarantee has to be entered into and it has to

22 be signed off on by the guarantor.

23 Q. Right. I move on to the next subject. Do you recall

24 there being an internal investigation within the Bank

25 where you were asked various questions about witnessing

42 :1 Mr Arkhangelsky’s signature under the guarantees?
2 A. So far as I can recall, in 2009 some investigations by

3 the internal audit department were actually conducted,

4 and amongst other things they looked into all the files,

5 the dossiers, all the documents that they believed

6 needed to be in place, and they may have asked me, or

7 some other employees, to provide explanations.

8 Mind you, this is, again, a routine job, whereas

9 when a major client falls in arrears, then people start

10 looking at those loans with a magnifying glass, very

11 carefully indeed.

12 Q. But was there — I think what I have in mind, there was

13 an investigation carried out by the security department

14 of the Bank; do you recall that?

15 A. Not that I can recall that. We do have what we call the

16 internal audit department within the Bank, and I do

17 recall that they did conduct some investigations.

18 Someone else may have conducted further investigations,

19 but I have no recollection of that. No specific

20 recollection of that.

21 Q. I beg your pardon, my Lord, it may, again, take a little

22 time. I would like to put a certain document. I may

23 come to this a little later.

24 Do you recall being ever questioned by the Russian

25 police about these matters?

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Arkhangelsky [Master]

43 :1 A. Yes, I do recall some government bodies, maybe the
2 police, asking questions. I don’t recall who, exactly,

3 that was. I do not recall which body of the Russian

4 government it was.

5 Q. Does the name Yulia Slavovna Levitskaya mean anything to

6 you?

7 A. No. No, not really. I cannot recollect that. I have

8 no recollection of that.

9 Q. Would you say that you were frightened as a result of

10 those investigations by Russian authorities?

11 A. No. Why would I be frightened? Questions were being

12 asked within the framework of my remit, within my

13 competence. What I could answer with respect to

14 the questions that were being asked of me, I did

15 provide.

16 Q. Right, Mrs Blinova, let me briefly come back to

17 the answers you gave yesterday about file F in

18 the disclosure. You will recall, the problematic debt

19 reports.

20 You didn’t expect to be questioned about that here,

21 did you?

22 A. Well, to be honest, I did not set myself the objective

23 to anticipate or pre-empt the questions that you were

24 about to ask of me.

25 Q. Well, I think you said yesterday that you did, and you

44 :1 expected you would only be asked questions about the
2 documents you exhibit, or about your witness statement;

3 don’t you recall saying that?

4 A. No. I did not say that I anticipated those questions to

5 be asked of me. If I am not mistaken, what I said was

6 approximately along the lines of the documents that

7 I attached to my witness statement included the first

8 version of the valuation reports with the wrong entry

9 with respect to 17 June, if I am not mistaken.

10 Again, speaking from memory, what I said was that

11 I was referring to those documents in my witness

12 statement.

13 Q. Yes, Mrs Blinova. Well, I think I should say, even

14 though, perhaps, I was unkind to you on occasions during

15 this cross-examination, there is one bit of your

16 evidence which I accept and, indeed, I commend you for

17 your truthfulness, and that’s what you told us about

18 what you could remember about this file F matter.

19 Now, my question is, are you worried about what

20 might happen to you or to your family in Russia because

21 of the evidence you have given?

22 A. My apologies, could you be more specific?

23 Q. Well, I think it’s a clear answer. Do you think there

24 may be any repercussions for you in Russia as a result

25 of giving that evidence?

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Arkhangelsky [Master]

45 :1 A. Repercussions on the part of who? Who would be the
2 source of those repercussions, or repression? I fail to

3 see who the source might potentially be, in my mind.

4 MR STROILOV: I think that’s a clear enough answer. Let me

5 quickly check I haven’t omitted anything too important.

6 Thank you very much, Mrs Blinova.
7 Re-examination by MR LORD
8 MR LORD: Ms Blinova, could you please be shown {B2/9/19},

9 because it was just put to you by Mr Stroilov that you

10 didn’t expect to be asked any questions about the

11 problematic debt reports he asked you about yesterday.

12 A. My apologies, I am looking for the Russian version as

13 well.

14 Q. If you could be helped to find the … {B2/9/43}, it is

15 paragraph 116 of your witness statement. Ms Blinova,

16 are you, in that paragraph, referring to these

17 problematic debt reports that Mr Stroilov has asked you

18 many questions about?

19 Can I please ask you about your evidence about the

20 personal guarantee.

21 MR JUSTICE HILDYARD: What was the answer to that question?

22 It hasn’t been recorded.

23 MR LORD: Sorry, my Lord.

24 A. Yes, I can see 116 where I am making reference to the

25 bad debt report.

46 :1 MR JUSTICE HILDYARD: The bad debt reports in F, are you
2 saying? In bundle F?

3 A. I’m now referring to 116, paragraph 116 of my witness

4 statement, which we now have on the screen.

5 MR JUSTICE HILDYARD: I am just trying to clarify in my mind

6 what reports you are referring to in paragraph 116.

7 A. My understanding is that Mr Stroilov asked me a question

8 as to — I’m trying to recall exactly how he formulated

9 this question, and that was with respect to our

10 yesterday’s discussion of the bad debts report, and in

11 this paragraph I am making reference to the reports

12 which are annexed to my witness statement.

13 MR JUSTICE HILDYARD: Yes.

14 A. And they appear in square brackets here.

15 MR JUSTICE HILDYARD: Thank you very much.

16 MR LORD: And I wonder if we could please click on the

17 exhibits that you exhibited there, please. I think it

18 will be {D5/122/1}. If you go to {D5/124/1} sorry, my

19 fault. Can we have {D5/123/1}. My fault. I just want

20 to establish, Ms Blinova, what reports you exhibited to

21 your witness statement. Can we have the Russian — is

22 it possible to have the Russian version as well on the

23 other screen. {D5/123/5}. Thank you.

24 Can we scroll down, please, page by page, just in

25 this report. One more page, please. Then one more,

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Arkhangelsky [Master]

47 :1 please. Can you see those pages, Mrs Blinova? Do you
2 have the Russian version?

3 A. Yes.

4 Q. And you can see that the version of the report that you

5 exhibited contained the entry for 17 June 2009, didn’t

6 it?

7 I think it was suggested to you that there has been

8 some tampering with these reports so as to hide the

9 17 June 2009 entry; do you want to deal with that in

10 the light of this exhibit to your witness statement,

11 Ms Blinova?

12 A. What I would like to emphasise is that I tried to

13 recollect what had happened, I tried to do that

14 yesterday, and so in order to make the changes that may

15 have been made in the autumn of 2009, even though

16 I still do not recall the details very well, so what was

17 done was to make those reports consistent with the

18 actual reality. It may have come to my attention that

19 this had actually not happened, that this event had not

20 taken place, and so I thought it appropriate, and

21 I think that it was the right thing to do, I tried to

22 make those reports consistent with actual reality, but

23 the way I understand it, two versions are still in

24 existence, and I think this is quite appropriate because

25 at some point in time those reports were being filed

48 :1 with the various bodies, and so I needed to have some
2 written confirmation as to why I had been sending that

3 information on.

4 Then some adjustments were made and, as we saw

5 yesterday, they are signed off on by my director. So he

6 re-executed those reports.

7 Q. And so, in answer to the question, or the point put to

8 you by Mr Stroilov that there has been an attempt on

9 behalf of the Bank to hide, to conceal the entry, the

10 record on 17 June, can you, on oath, tell his Lordship,

11 please, now, what your answer is to that?

12 A. Well, I obviously did not try to conceal or hide

13 anything and, as I was preparing to give evidence,

14 I obviously did peruse those reports that have been

15 annexed hereto and we do have the 17 June entry here.

16 So I was quite surprised — or maybe not surprised —

17 I just could not recall exactly what had happened.

18 But I can see that it’s there and I did not try to

19 conceal this.

20 MR JUSTICE HILDYARD: Can I just ask this in case —

21 MR LORD: Yes, my Lord.

22 MR JUSTICE HILDYARD: — and I’m so sorry to be so silly

23 about this, but which was the first version and which

24 the second? Were the reports which do include the

25 reference to 17 June the corrected reports, adding

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Arkhangelsky [Master]

49 :1 something, or were the file F reports, which didn’t have
2 that entry, corrections of this report? Which way round

3 was it?

4 A. So what originally happened was the documents that are

5 annexed to the witness statement, and that do include

6 17 June were the primary records, as it were, then what

7 happened next was something that Mr Stroilov showed me,

8 and that was when that entry was deleted.

9 MR JUSTICE HILDYARD: Right. So that was the sequence:

10 Your first reports, which are exhibited, contained the

11 reference to 17 June, but then you were told to delete

12 those and the records in F which do not include that are

13 your corrected versions in accordance with the

14 instructions that you had received; is that right?

15 A. That is correct, my Lord. That’s my understanding of

16 the position as of today.

17 MR JUSTICE HILDYARD: Thank you.

18 MR LORD: Ms Blinova, can I ask you, please, Mr Stroilov,

19 I think suggested to you, that when the Bank was

20 entering into some of these loans with OMG companies,

21 they were not really interested in getting a personal

22 guarantee from Mr Arkhangelsky; it was really just

23 something, it was really just a sort of tick in the box

24 and they were not interested in getting an actual

25 guarantee from you; do you remember those questions this

50 :1 morning?
2 A. Yes, I do recall that.

3 Q. Can you please be shown — I would like to show you,

4 please, some of the management board resolutions in

5 respect of the Vyborg loans. I wonder, please could you

6 be shown — can we have {D36/615/1} and also

7 {D36/615/4}, so pages 1 and 4, please.

8 Ms Blinova, this is an extract from the management

9 board minutes for BSP in relation to the first Vyborg

10 loan in March 2008.

11 Your Lordship will find it helpful, it is in

12 the contracts bundle, my Lord, if that would be helpful.

13 MR JUSTICE HILDYARD: Thank you.

14 MR LORD: Behind divider 15. Bundle A to C.

15 Can you see, Ms Blinova, that if you go to

16 {D36/615/1} you can see the first page of the executive

17 board resolution for 26 March 2008; can you see that?

18 A. Yes, I can see that.

19 Q. And if you look down to the number 19.1 — well, you can

20 see item 19 is the question of «Extension of loans to

21 Vyborg Shipping Company»; do you see that?

22 A. Yes, it sets the limit.

23 Q. And you can see, can’t you, that in the rest of

24 paragraph 19, there is a record of further aspects of

25 the board’s resolution; you can see that, can’t you?

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Arkhangelsky [Master]

51 :1 A. Yes.
2 Q. And can you see 19.1.1, which reads as follows in

3 the translation — and please correct it if it is

4 different in the Russian:

5 «The following shall be accepted as the security

6 against each of extended loans.»

7 Is that right?

8 A. That is right, yes.

9 Q. And then there are a series of subparagraphs, which seem

10 to identify a security that’s going to be given; is that

11 right?

12 A. Absolutely, that is correct.

13 Q. And you see a pledge of real estate, reference to

14 a vessel, and then mortgage agreements; and can you see

15 the third subparagraph? It looks, in the translation,

16 it has been translated as this:

17 «Guarantee of VD Arkhangelsky without financial due

18 diligence.»

19 Is that an accurate translation of the Russian

20 minute?

21 A. Yes. In Russian it says:

22 «Guarantee by VD Arkhangelsky without financial due

23 diligence of the guarantor.»

24 Q. In your experience, would you expect the management

25 board of the Bank of St Petersburg to resolve to enter

52 :1 into a loan on the basis of a guarantee but then not go
2 ahead and expect that guarantee to be executed?

3 A. We have not had any instances like that.

4 Q. Thank you, Ms Blinova. I have one more area to cover.

5 Ms Blinova, I think it was put to you this morning

6 by Mr Stroilov that you didn’t send any demand notices

7 under the personal guarantees to Mr Arkhangelsky.

8 I will be corrected if I have that wrong, but I think

9 that was what was suggested to you this morning; do you

10 remember that line of questioning? Do you remember it?

11 Just wait for the next question, but do you remember

12 that questioning?

13 A. Yes, of course, I do. He did say that Mr Arkhangelsky

14 had not received anything from me. That was what was

15 being put to me.

16 Q. He did say that, and I think in fairness to you,

17 Ms Blinova, I would like to show you some documents that

18 have come from Mr Arkhangelsky’s records in this regard.

19 I wonder, please, if we could first have {M1/20/30}.

20 Ms Blinova, I am afraid there is only an English version

21 of this document, so what I will have to do, I think, is

22 to orientate you and then explain to you, or have the

23 translators explain to you, the relevant passages that

24 I think you need to be apprised of.

25 So this is the first affidavit of Mr Arkhangelsky,

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Arkhangelsky [Master]

53 :1 which he swore in the BVI legal proceedings. You will
2 see at {M1/20/69} where Mr Arkhangelsky seems to have

3 sworn this affidavit; do you see that?

4 A. One second, please.

5 Q. He has concluded it by saying, and I will translate

6 paragraph 228:

7 «I believe this affidavit has been sworn in

8 accordance with the laws of France.»

9 Can you see that? And it has been sworn to be true,

10 before a notary, a French notary.

11 Then I wonder if you could, please — or if we could

12 have {M1/20/30} on screen. I am going to read this out

13 to you, Ms Blinova, because obviously it is in English.

14 At paragraph 80, Mr Arkhangelsky deposed as follows:

15 «Around the middle of April 2009 —»

16 Paragraph 82, sorry, my fault. Paragraph 82 reads:

17 «Around the middle of April 2009, the Bank started

18 demanding early repayment of the loans which it had made

19 to Vyborg Shipping.»

20 Then the paragraph read on:

21 «At pages 394 to 406 of ‘VA1′ I have exhibited

22 a Notice of Claim issued by the Bank dated 14 April 2009

23 and associated documents stating …»

24 And then there is a quotation from that exhibit.

25 The reference there, Ms Blinova, to the exhibit, was to

54 :1 some exhibited documents which Mr Arkhangelsky had
2 attached to this affidavit. If those could please be

3 turned up on Magnum, can we please have {D118/1796/0.1}.

4 It should be possible to show where this document came

5 from. Could you back to the index to show, on the

6 right-hand side, I think it shows that this was from the

7 defendants’ disclosure.

8 MR STROILOV: I don’t think I dispute that. I think it

9 comes from …

10 MR LORD: That’s very helpful, Mr Stroilov, I wasn’t sure,

11 because this is obviously in the D run and I wasn’t sure

12 if you …

13 So, Ms Blinova, it is accepted that this document

14 was exhibited to Mr Arkhangelsky’s affidavit in the BVI.

15 Can you please scroll down this exhibit and can you

16 end up at {D118/1796/9}. You can see there, Ms Blinova,

17 that this is an extract from a document that

18 Mr Arkhangelsky exhibited to the BVI affidavit of his,

19 and he has set out various e-mails and he has numbered

20 them; can you see that?

21 A. Yes, I do.

22 Q. 4, 5, 6 on this page. Can you see e-mail number 5?

23 A. Yes, I can.

24 Q. And you have the Russian there, because Mr Arkhangelsky

25 exhibited — he extracted the Russian version, and he

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Arkhangelsky [Master]

55 :1 also interposed an English translation beneath.
2 A. Yes, yes, I can see that.

3 Q. Do you follow that? And can you confirm to his Lordship

4 that the e-mail — the Russian version of the e-mail

5 seems to be an e-mail from you on 1 April 2009?

6 A. Yes, I can see that my e-mail is stated here, and I can

7 see who the e-mail was sent to. What I understand is

8 that that is Mr Arkhangelsky’s address.

9 Q. And can you tell his Lordship — it is a short e-mail,

10 I’m not sure the translation is exactly right — could

11 you just tell his Lordship what that e-mail says in

12 Russian?

13 A. «Vitaly Dmitrievich, good afternoon. With regard to

14 the delayed debts under the loan agreement number

15 3500-08-01203 dated 28 March 2008, concluded with

16 Vyborg Shipping Company JSC, I notify you that in

17 compliance with the guarantee agreements entered into

18 between Arkhangelsky VD and Scandinavia Insurance

19 Company, today the direct debits would be issued against

20 all accounts of the guarantors.»

21 Q. If we could please now go to {D117/1737/1} because,

22 Ms Blinova, that extract and the attachment does not

23 have the full e-mail. It doesn’t have the attachment to

24 the e-mail. So if you could be shown {D117/1737/1},

25 please, and if we could have the Russian — if it is

56 :1 possible to have the Russian page, if we can, on the
2 screen, so Ms Blinova could follow that. {D117/1737/4}.

3 Can you see that, Ms Blinova?

4 A. Yes, I can.

5 Q. It involves a bit of hopping around, but if you look at

6 the Russian at {D117/1737/4}, if you look at that e-mail

7 there, you can see that it looks to be the same e-mail

8 that Mr Arkhangelsky exhibited back in the BVI. If we

9 could go back to that just for a second, please,

10 {D118/1796/9}. Can you just look at those two, the

11 Russian, the two versions of that e-mail; it looks to be

12 the same document, doesn’t it, Ms Blinova?

13 A. Yes, I think — yes. It is the same document.

14 Q. If you could, please, go back to {D117/1737/1}, can you

15 see, Ms Blinova, that in the Russian, you appear to have

16 attached — there are two attachments, seemingly, to

17 your e-mail of 1 April 2009 to Mr Arkhangelsky, aren’t

18 there?

19 A. Yes. As far as I can see in the Russian version, one

20 can see two attachments, apparently notifications of

21 demand.

22 Q. Yes. And if we could scroll down, please, and again,

23 I think we need to scroll down, if you don’t mind,

24 please, in the English and the Russian. If you do it

25 sort of page by page, you can see that there is a claim

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Arkhangelsky [Master]

57 :1 notification to the general director of Scan; can you
2 see that? {D117/1737/2}. So it looks like it is

3 a notification to Scan Insurance, who are one of

4 the guarantors, can you see that? That’s at

5 {D117/1737/5}.

6 A. Yes, I do. I can see that.

7 Q. Then if we could please scroll down another page, can

8 you see that at {D117/1737/6} in the Russian and

9 {D117/1737/3} in the English, that there appears to be

10 a claim notification addressed to Mr Arkhangelsky

11 himself; can you see that, Ms Blinova?

12 A. Yes, I can see that.

13 Q. Having seen these documents, does it look as if what

14 happened on 1 April 2009 was that you sent an e-mail to

15 Mr Arkhangelsky, including as an attachment a demand to

16 him under his personal guarantee?

17 A. Yes. I think it looks — this is exactly what I did.

18 MR LORD: Does your Lordship have any questions of this

19 witness?

20 Questions by MR JUSTICE HILDYARD

21 MR JUSTICE HILDYARD: Yes, one or two. I’m so sorry to keep

22 you.

23 In your witness statement — and I’m really just

24 trying to pick your brains here — at paragraphs 95 and

25 107, and possibly elsewhere, you refer to the

58 :1 requirement to make reserves if the borrowers were not
2 going to repay, and you say, for example, in 95

3 {B2/9/16}:

4 «I prepared a note setting out the possible levels

5 of reserves if the OMG borrowers were not going to

6 repay.»

7 That was part of your responsibilities, was it, to

8 recommend reserves?

9 A. Yes, my Lord. One could put it this way: the reserves

10 were created strictly in accordance with the

11 Central Bank guidelines. I was simply stating the fact

12 that on such and such date, such and such reserve could

13 be created.

14 MR JUSTICE HILDYARD: And I rather got the impression from

15 the previous witness that the reserve made would be in

16 the amount of the debt outstanding; is that right or

17 would it be a slightly lesser amount than that, or

18 greater?

19 A. The system was quite complex, the system of evaluating.

20 There were various risk categories with regard to

21 debtors, and the reserves are formed according to that.

22 To put it roughly, the reserves could be from

23 anywhere between 1 and 100 per cent of the indebtedness.

24 However, with the passage of time, the longer the

25 arrears are, the higher the reserves are at the balance

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Bank St Petersburg v Vitaly Day 5
Arkhangelsky [Master]

59 :1 of the branch, and they are graduated, if I am not
2 mistaken, if they are five days overdue, if they are up
3 to 30 days overdue, and if the arrears are over and
4 above 30 days. I do not exactly remember the figures,
5 but the interest is also growing with the growing of
6 the overdue term of the indebtedness.
7 MR JUSTICE HILDYARD: And those scales are mandated by
the
8 Central Bank or by the central office at the
9 St Petersburg Bank; which?
10 A. The Central Bank. The Central Bank is the primary body
11 that issues the relevant instructions and provisions,
12 and all the other banks look up to that.
13 MR JUSTICE HILDYARD: So by the end of, say, 30 days,
taking
14 that as an example, the full amount of the debt would
15 have to be the subject of a reserve, of a provision?
16 A. I do not recall exactly, to be honest, with regard to
17 the number of days, but it’s about that way.
18 And we are not just talking about the overdue debts.
19 The risk group is set for the client as a whole, even if
20 part of the debts are not overdue, the reserves have to
21 be created for that nevertheless, using the same
22 interest as for the debt in arrears.
23 MR JUSTICE HILDYARD: Thank you.
24 Now, in various parts of your witness statement and
25 in your evidence today and yesterday, you described the
60 :1 process of sending out default letters; would you be
2 given instructions to do so or would that also be part
3 of your remit? Which?
4 A. That was part of my remit. I had to track the arrears
5 as and when they would arise, and to do the relevant
6 work.
7 MR JUSTICE HILDYARD: Right. Now, in the case of demands
8 under the personal guarantees, there is a slight, as
9 I read it, equivocation as to whether, in every case,
10 demands under the personal guarantees, as distinct from
11 demands under the primary documentation, were sent by
12 registered mail. Were they always sent by registered
13 mail in the case of personal guarantees?
14 A. Put it this way: the actual process of sending the
15 letter was not controlled by me. The way I put it,
16 I asked it to send — the way I put it by registered
17 letter with the notification of delivery. So the letter
18 would be delivered by postman, and then the person
19 receiving it would have to sign off, saying the letter
20 has been received by them. This is what I asked the
21 responsible person to do, the person who was in charge
22 of sending letters.
23 MR JUSTICE HILDYARD: Thank you. So, so far as you were
24 concerned, your instruction to that person was, in
25 the case of any demands, whether under the personal

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Arkhangelsky [Master]

61 :1 guarantees or under the primary loans, that they should
2 be sent registered post? That was your instruction to

3 that person?

4 A. Yes.

5 MR JUSTICE HILDYARD: Yes, thank you.

6 Were any documents making demands under the personal

7 guarantees to your knowledge returned but never reposted

8 by registered mail?

9 A. I recall that a number of documents were returned,

10 however, I re-sent them every time when they were

11 returned.

12 MR JUSTICE HILDYARD: In every case so far as you are aware

13 and can remember?

14 A. I recall that the letters sent personally to

15 Mr Arkhangelsky and not to some corporate address, not

16 to the borrower, not to the second guarantor, these were

17 the letters that came back most often. I remember

18 I conferred, probably with my direct manager, whether it

19 was possible to send these letters not just to

20 the address stated in the guarantee agreement, but to

21 other letters known to the Bank, for example, to

22 the spouse’s address, that were stated in the consents,

23 and I received such consent. As far as I recall, we

24 duplicated, made several copies of such notices of

25 demand, and I sent them to other addresses. I think to

62 :1 Blagodatnaya Street and to Kharkovskaya Street. Now
2 I cannot recall exactly the chronology of these events,

3 but I recall that I sent the letters several times.

4 MR JUSTICE HILDYARD: You refer in that context in

5 paragraph 113 of your witness statement to your

6 realisation that a typographical mistake had been made

7 in respect of Mr Arkhangelsky’s address. How did that

8 emerge? How did you come to realise that?

9 A. I think I realised it quite quickly, but around from the

10 moment of sending the first few letters to that address,

11 as far as I recall, perhaps a week or two would pass and

12 the letter would come back and the address would be

13 crossed out, saying that: this address does not exist,

14 or some such wording. Then I started checking, using

15 the documents available at the Bank, using the copy of

16 the passport, and I saw the mistake and I saw that it

17 should not be Dobrolyubova Street, but Dobrolyubova

18 Prospekt, Dobrolyubova Avenue, and I re-sent the

19 letters.

20 The second time round, if a few of them accumulated,

21 say, three or four letters were returned, I could have

22 put them all together in the same envelope and sent

23 a bunch of letters.

24 MR JUSTICE HILDYARD: Thank you.

25 A small question on paragraph 44 of your witness

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Arkhangelsky [Master]

63 :1 statement, where you explain that, as documents were
2 often prepared in a hurry, they might contain errors,

3 and sometimes needed to be corrected. But you state

4 that if that happened, then the documents would be sent

5 to OMG and they would return the corrected versions.

6 {B2/9/8}.

7 So far as you are aware, was that invariable, that’s

8 to say, if an error was detected, it was always sent

9 back for re-signature by OMG with the corrected version?

10 A. As I mentioned already, yes, if an error would be

11 detected, usually the administration department or our

12 lawyer would ascertain such an error, then everything

13 would depend on the situation.

14 For example, if a borrower, in particular,

15 Mr Arkhangelsky, because he was visiting the Bank quite

16 often, and as far as I recall he didn’t have anything

17 against re-signing any documents if necessary, then we

18 could re-sign some specific pages right there at the

19 Bank.

20 However, most often these amendments needed to be

21 done as soon as possible, and then I would e-mail them,

22 either just the cut-out pages or the entirety of

23 the documents or the agreement, and I asked, for

24 example, to print the second page and re-sign it, and

25 I would explain what the typo was or what the inaccuracy

64 :1 was.
2 And, if I may, I could add that here I amended

3 typos, not some serious mistakes or errors, but simply

4 a typo in a word, or perhaps there was, instead of

5 a dash, some other sign, something small.

6 MR JUSTICE HILDYARD: Some small thing, yes, editorial?

7 A. Exactly.

8 MR JUSTICE HILDYARD: Paragraph 50, just on the next page of

9 your witness statement {B2/9/9}, as I understand it, the

10 context is the fourth Vyborg loan, you refer in the last

11 paragraph to the fact that Vyborg had:

12 «… also failed to provide the direct debit

13 agreements with other banks in respect of the borrower

14 and guarantor.»

15 Does that signify that in the case of the fourth

16 Vyborg loan the personal guarantee which is relied on,

17 if it was such, was intended to be supplemented by some

18 direct debit agreement?

19 A. Yes, it follows from my witness statement that the most

20 likely when the decision was made with regard to

21 the fourth loan, perhaps such provision was encompassed

22 there about provision of the direct debit agreement.

23 MR JUSTICE HILDYARD: Why was it considered — are you

24 aware, you may not know, but do you know why it was

25 considered that it should be supplemented, the personal

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Arkhangelsky [Master]

65 :1 guarantee should be supplemented by direct debit
2 arrangements in the context of the fourth Vyborg loan,

3 but not in the context of the first? Or is that premise

4 wrong?

5 MR LORD: Sorry, my Lord, I think it is premised —

6 your Lordship will know that there are two guarantors.

7 There is the Scan guarantor — I don’t want

8 your Lordship to make a mistake.

9 MR JUSTICE HILDYARD: No.

10 MR LORD: It is right to show your Lordship. If

11 your Lordship has the contracts bundle, one can see

12 this, that —

13 MR JUSTICE HILDYARD: I should have asked the witness: can

14 you remember which guarantor you are talking about in

15 paragraph 50?

16 A. I think I am talking about the Scandinavia Insurance

17 guarantor.

18 MR JUSTICE HILDYARD: Not Mr Arkhangelsky?

19 A. I can’t recall that we had any tripartite agreements

20 with Mr Arkhangelsky.

21 MR JUSTICE HILDYARD: At any time in respect of any of

22 the loans?

23 A. I do not recall.

24 MR JUSTICE HILDYARD: All right. Thank you very much.

25 MR LORD: My Lord, I was going to show your Lordship — if

66 :1 I could just show your Lordship, I think it is probably
2 appropriate, so your Lordship just has it in the record,

3 as it were.

4 MR JUSTICE HILDYARD: Yes, absolutely.

5 MR LORD: In A to C, if your Lordship would be kind enough,

6 please, to go behind B. B is the first Vyborg loan, and

7 I will show you the other versions of the other loans,

8 but starting with the first one, behind divider 15 of

9 that bundle are various excerpts from minor, major and

10 executive board committees.

11 MR JUSTICE HILDYARD: Yes.

12 MR LORD: So your Lordship understands, rather than having

13 too many tabs, these have just been sort of filled in.

14 If your Lordship would go, please, towards the end of

15 that divider, {D36/615/1}.

16 MR STROILOV: I’m sorry to interrupt, is there any copy of

17 this, hard copy of this —

18 MR LORD: {D36/615/1} on Magnum. Your Lordship will see,

19 and I took the witness to this.

20 MR JUSTICE HILDYARD: Yes, you did.

21 MR LORD: And this was the executive board resolution for

22 the first Vyborg. Your Lordship will see I took the

23 witness to the references to «guarantees» about a third

24 of the way up from the bottom, there is one from

25 Mr Arkhangelsky without due diligence and then there is

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Arkhangelsky [Master]

67 :1 one from Scandinavia Insurance Company.
2 MR JUSTICE HILDYARD: Yes.

3 MR LORD: If one goes over the page, this is apposite to

4 your Lordship’s point, at 19.1.6 and 19.1.7, I trust

5 your Lordship can see the distinction.

6 MR JUSTICE HILDYARD: I can see.

7 MR LORD: I haven’t checked the second, 234, but I will

8 arrange for that to be done now and if there is any

9 discrepancy I will deal with it.

10 MR JUSTICE HILDYARD: Anyway, so far as you recall,

11 Ms Blinova, there were no such arrangements with respect

12 to any of the personal guarantees which the Bank relies

13 on? Personal guarantees, not Scan guarantees.

14 A. Yes, your Lordship, I cannot recall that we had any

15 tripartite agreements with regard to a personal

16 guarantee.

17 MR JUSTICE HILDYARD: Yes. Now, my last question is

18 a general one, and I put it in fairness to you and to

19 Mr Stroilov, lest I interrupted him. I believe, on

20 reflection, that what was, or might have been, being put

21 to you is that your witness statement was a document

22 which you were told to sign without regard to its detail

23 or truth; what do you say about that?

24 A. I would like to say that this is absolutely not the

25 case. No one forced me to sign the witness statement.

68 :1 This is a false assumption, a false assertion of
2 Mr Stroilov.

3 MR JUSTICE HILDYARD: Right. Thank you very much.

4 Does anyone have questions arising from that?

5 Mr Stroilov, I hope that I have encapsulated what

6 I think, on reflection, you might have been wishing to

7 put, but if it has inspired you to any other controlled

8 question, then of course you must put it. I don’t want

9 you to feel that that which you wanted to put to

10 the witness had not been put to her.

11 MR STROILOV: I’m very grateful, my Lord. I think that’s

12 exactly what I meant to say and you have formulated it

13 better than I, with respect.

14 I think I got a — I’m not quite sure, to be honest,

15 about what are my procedural rights at this stage.

16 I have a couple of questions in terms of — well,

17 arising, I hope, either from re-examination or from

18 your Lordship’s questions.

19 MR JUSTICE HILDYARD: You have no right in respect of

20 questions arising from re-examination. You do have

21 a right in respect of questions which I have put.

22 Further cross-examination by MR STROILOV

23 MR STROILOV: I think I’ve only got one.

24 When my Lord referred to registered post, you

25 remember his Lordship asked you whether you have

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Arkhangelsky [Master]

69 :1 directed people to send notices by registered post, just
2 to be sure so that there is no confusion — because

3 I believe there has been confusion on that — by

4 «registered post» you mean zakaznoyes uvedeomleniyem?

5 A. Yes, I meant — I am not a specialist in this regard.

6 I meant a letter. When someone receives this letter

7 they have to sign a card saying they received the letter

8 and that card would be then coming back to us as the

9 sender. This is the letter I meant. Unfortunately I do

10 not know the exact term.

11 Q. The reason I am asking is because Russian banking

12 experts were confused about terminology, so I wanted to

13 take advantage of my Russian and Mrs Blinova’s.

14 MR JUSTICE HILDYARD: Very well.

15 MR STROILOV: Thank you very much.

16 MR LORD: My Lord, there is just one further point, on the

17 [draft] transcript today, before the witness goes, there

18 is a wrinkle that I have identified needs to be put.

19 Could we please have page 13 from today, and I am

20 instructed that there has been an error in translation

21 at [draft] lines 15 to 16 {Day5/13:15}.

22 Can your Lordship see between lines 14 to 16, it

23 says:

24 «There are two things here, there is the

25 psychological side with regard to the pledge and, of

70 :1 course, the undoubted financial side to the pledge».
2 And I understand from the context, your Lordship

3 will recollect the context, it is tolerably clear but

4 I think the witness —

5 MR JUSTICE HILDYARD: The guarantee.

6 MR LORD: Exactly, and I don’t want this point to go — it

7 may be no issue and it could be — the translators are

8 doing a fantastic job and I am not being at all

9 critical, but I was just asked if that could be checked

10 or confirmed that it should read «guarantee» in both

11 those places at that point in the transcript.

12 MR STROILOV: That looks right at the first glance. Well,

13 I wonder if, perhaps, my learned friend can read this to

14 Mrs Blinova just so that we are sure whether that’s what

15 she meant in the mistranslated, and — because it is her

16 evidence, and I was listening to this in the headphones,

17 so in a way I may have missed it.

18 It certainly makes sense to substitute «guarantee»,

19 but let’s ask the witness, perhaps.

20 MR LORD: Well —

21 MR STROILOV: Shall I try again?

22 MR LORD: Is it possible that the translators can listen to

23 it now?

24 MR JUSTICE HILDYARD: It may be difficult to recapture that.

25 I just don’t know.

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Arkhangelsky [Master]

71 :1 MR LORD: I am told that Elena Edwards, the translator, has
2 confirmed that that was a mistake.

3 MR JUSTICE HILDYARD: Right. It sounds right because «the

4 psychological part of the pledge» seems quite esoteric.

5 MR LORD: Sorry, my Lord, I didn’t want that to go lest it

6 be thought that somehow the witness — my Lord, unless

7 your Lordship has any further questions for Ms Blinova,

8 could she be released?

9 MR JUSTICE HILDYARD: No. Ms Blinova, thank you very much.

10 I am sorry to have detained you. I hope you have a good

11 journey back.

12 I will have one request in respect of all witnesses,

13 and I make it now in case logistically it is easier to

14 do it, which is that I would like photographs of each

15 witness because, as the trial goes on, it is very

16 helpful to have a record. It always surprises me we

17 don’t require it in witness statements, and I should be

18 awfully grateful if arrangements could be made. As

19 I say, I raise it now in case Ms Blinova is going away

20 somewhere and it would be more difficult.

21 MR LORD: She is going back to Russia.

22 MR JUSTICE HILDYARD: Yes. Okay. Thank you very much

23 indeed.

24 A. Thank you, my Lord.

25 (The witness withdrew)
72 :1 MR JUSTICE HILDYARD: Right. Where have we got to?
2 Housekeeping
3 MR LORD: My Lord, obviously I see the time. Just very

4 quickly, in terms of timetabling, we gave some thought

5 to your Lordship’s observations yesterday —

6 MR JUSTICE HILDYARD: Yes.

7 MR LORD: — and Mr Stroilov’s submissions, and we have

8 worked on a rescheduling of this week and next, in

9 order, we hope, to accommodate both those sets of

10 positions. The upshot of which is as follows: that in

11 order that there be no suggestion of compression of

12 these first two weeks, we actually have Ms Patrakova

13 after the short adjournment, who is here and must

14 necessarily go back, a short witness.

15 MR JUSTICE HILDYARD: Yes.

16 MR LORD: And then we call Ms Shabalina as the next witness.

17 She is down for this week but she was going to be,

18 I think, after Ms Yashkina.

19 Mr Stroilov indicated that he would be half a day

20 with Ms Shabalina and a day with Ms Yashkina, and

21 Ms Shabalina does not work for the Bank and she needs

22 a fixed slot.

23 So what we propose, with your Lordship’s permission,

24 is to call Ms Patrakova today, and then deal with

25 housekeeping today, or maybe even stop early, to allow

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Arkhangelsky [Master]

73 :1 Mr Stroilov, of course, to do his preparation. Then to
2 call Ms Shabalina tomorrow, and, again, that would be

3 the end of the witness evidence this week.

4 Next week, we are mindful of your Lordship’s point

5 in respect of Mr Savelyev, and Mr Stroilov’s points in

6 that regard about the time to prepare, and, looking at

7 the timetable and trying to do our best to rejig things,

8 we are proposing to call Mr Guz, who will fly back from

9 Russia, for next week, to be the first witness next

10 week, on Monday, with a possible spill over into

11 Tuesday, Mr Stroilov having indicated he might need up

12 to two days with Mr Guz.

13 Then we are proposing calling Ms Volodina, who is

14 also currently down for next week, on Wednesday, with

15 a view to spilling over into Thursday, if necessary.

16 Again, Mr Stroilov has indicated that he might need up

17 to two days with that witness, and then we would hope to

18 finish comfortably by the end of Thursday, with normal

19 court sitting hours. We are obviously mindful of

20 the need to have four-day weeks for all concerned. That

21 would allow, hopefully, Friday off, of both this week

22 and next.

23 The following week we have Ms Stalevskaya for

24 Monday 15, and we would propose to call her before we go

25 to Paris. That would obviously mean we are going to

74 :1 have to stand over Mr Savelyev, Ms Yashkina and
2 Ms Mironova until after Paris, and we will consider how

3 to reschedule them and give due notice. But that,

4 I think, will take us, my Lord, through at least the

5 next two to three weeks of the trial. We are conscious

6 that Mr Stroilov needs notice of the witness line-up and

7 we will of course give him more than enough time and we

8 will obviously consult with your Lordship.

9 The aim is really to ensure efficient dispatch of

10 these two weeks. We are, unfortunately, going to lose

11 some time in terms of witnesses who will have to be

12 stood out, but we have taken on board all that was said

13 yesterday, and without in any way accepting that the

14 subsequent timetable needs to be as flexible or elastic

15 as the first two weeks has turned out, but not in any

16 way being prescriptive, but reserving my position in

17 terms of how much time might be appropriate after Paris,

18 we hope that that new timetable will find favour with

19 your Lordship.

20 MR JUSTICE HILDYARD: And this has been shared with — well,

21 do you want to consider that and give me your response

22 at 2.00?

23 MR STROILOV: Perhaps, my Lord. It is obviously the first

24 time I have heard of that proposal, I can give immediate

25 indications if that assists.

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Arkhangelsky [Master]

75 :1 MR JUSTICE HILDYARD: Does it look all right at first blush?
2 MR STROILOV: No, it doesn’t, my Lord. I just can’t go on

3 at this pace, I am afraid. I have done my best, but the

4 basis of our proceeding was that I asked for six weeks,

5 your Lordship thought my cross-examinations would be

6 a lot shorter than I think, my learned friends thought

7 the same, and your Lordship said: we are going to see

8 how it goes.

9 MR JUSTICE HILDYARD: Are you worried about Ms Shabalina?

10 What are you worried about?

11 MR STROILOV: What I would have in mind, really, is that

12 I would — if, perhaps, we could have a slightly —

13 well, I am just finding — what I would try to do,

14 I think, is to — I would like to finish with

15 Mrs Shabalina today. It may be possible.

16 MR JUSTICE HILDYARD: With Ms Shabalina?

17 MR STROILOV: Yes, it may be possible to go through

18 Mrs Patrakova and Mrs Shabalina.

19 MR JUSTICE HILDYARD: I see.

20 MR STROILOV: I am concerned how well prepared I am and

21 perhaps over the short adjournment I could tell you

22 exactly. That would be what I would be aiming for, and

23 then I would request that I just can’t go on this week,

24 I need time to prepare for next week, where — well, if

25 there is no Mr Savelyev, then Mr Guz and Mrs Volodina —

76 :1 well, I think the two of them — well, I would need to
2 think about that.

3 MR JUSTICE HILDYARD: You think about it, discuss it with

4 Mr Lord. At some point we have to deal with this

5 wretched bank point and the question of cheques and

6 the — so I don’t know whether you can discuss that too.

7 Shall we start at 2.05 pm?

8 MR LORD: Yes, I think Ms Patrakova is the one-hour witness,

9 so I would hope, my Lord, that we do have enough time.

10 MR JUSTICE HILDYARD: Yes, but I think it is being suggested

11 to me that Mr Stroilov would like to start with

12 Ms Shabalina, whereas you had thought we would reserve

13 her for tomorrow.

14 MR STROILOV: No, I don’t think I have formulated correctly.

15 What I meant is I hope to finish with Ms Patrakova in

16 one hour and then use the remaining time for

17 Mrs Shabalina, and I would hope to finish it today.

18 MR JUSTICE HILDYARD: So you don’t have many questions

19 for —

20 MR STROILOV: No, Shabalina is not very big really.

21 MR JUSTICE HILDYARD: Is she here?

22 MR LORD: She is coming at 2.00 in case we get to her. We

23 told Mr Stroilov yesterday that we are going to bring

24 Ms Shabalina ahead of Ms Yashkina, as she is a shorter

25 witness and she has to be done this week. I want to be

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Arkhangelsky [Master]

77 :1 flexible, my Lord, we understand —
2 MR JUSTICE HILDYARD: It doesn’t matter to you whether she

3 is done this afternoon and finished off or half a day

4 tomorrow, I should imagine, and then perhaps you could

5 discuss whether there are any matters we have to address

6 on Thursday, or I take it Mr Stroilov would like both

7 Thursday and Friday to give him a clear run at preparing

8 for the next week.

9 MR STROILOV: And I don’t really think, if it goes to

10 tomorrow, I will need to consider very seriously leaving

11 her to Mr Arkhangelsky, and I don’t know, it may be much

12 better than my cross-examination, or it may be worse.

13 MR JUSTICE HILDYARD: Well, can I leave that for you to

14 consider, but it sounds to me as if you have prepared

15 Ms Shabalina and I wouldn’t want to waste that

16 preparation.

17 MR LORD: 2.10, my Lord?

18 MR JUSTICE HILDYARD: Do you want 2.10 in order to give you

19 a bit more time, it has been a difficult morning?

20 MR LORD: Yes, please.

21 MR JUSTICE HILDYARD: When are we going to deal with this

22 bank thing? After Ms Patrakova or when are we going to

23 deal with it? Have you been able to ascertain more

24 clearly what has happened?

25 MR STROILOV: Not really, and I would like to take more

78 :1 instructions and perhaps my learned friend too —

2 MR JUSTICE HILDYARD: Maybe after the short adjournment you
3 should do that and, therefore, we will defer until

4 2.10 pm. I think we must get on with Ms Patrakova first

5 thing, unless your instructions reveal an urgency

6 requiring the matter to be addressed today, in which

7 case I shall want to have a very particular explanation

8 of that.

9 MR LORD: My Lord, we would appreciate, we do not know what

10 this is about, and so if we can help and we can, in any

11 way clear some sort of problem, we do need proper,

12 specific notice of what the problem is and, therefore,

13 how it might be remedied.

14 MR JUSTICE HILDYARD: Yes. That is fair, is it not,

15 Mr Stroilov, because at the moment it’s vague, and

16 I think you need, and I need, and Mr Lord needs, more

17 detail as to what has happened and why.

18 MR STROILOV: Yes.

19 MR LORD: Thank you, my Lord.

20 MR JUSTICE HILDYARD: And anything that is said, I won’t

21 require a witness statement in advance, but I shall

22 require it to be confirmed, as a matter of good order,

23 by Mr Arkhangelsky, who I think must be the person who

24 has encountered the difficulty in France.

25 MR STROILOV: Yes, well that obviously — that takes some

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Arkhangelsky [Master]

79 :1 time to prepare, so I just ask you to —
2 MR JUSTICE HILDYARD: Yes.

3 MR STROILOV: My Lord, one more thing to flag, just so you

4 are aware, I’m likely to ask for, in the middle of that

5 hour I have for Mrs Patrakova, I am likely to ask for

6 a 10 or 15-minute break to take instructions. I think

7 you will see from the first half of cross-examination

8 why, but I just want that to be known.

9 MR JUSTICE HILDYARD: All right. So do you want to start at

10 2.15 pm?

11 MR LORD: Yes, please.

12 MR JUSTICE HILDYARD: Is that all right for you? It gives

13 you a bit more time to prepare.

14 MR LORD: Thank you, my Lord.

15 MR JUSTICE HILDYARD: 2.15 pm it is.

16 (1.13 pm)
17 (The Luncheon Adjournment)
18 (2.15 pm)

19 MR LORD: May it please your Lordship, there are still some

20 issues on the timetable but I suggest, with

21 your Lordship’s permission, we call Ms Patrakova and get

22 her done and then we deal with other matters.

23 MR JUSTICE HILDYARD: Yes.

24 MS NATALYA YURIEVNA PATRAKOVA (Affirmed)

25 (All questions and answers interpreted except where

80 :1 otherwise indicated)
2 MR JUSTICE HILDYARD: Thank you. Do sit down, I hope you

3 have some water. Let me know if you need a break.
4 Examination-in-chief by MR LORD
5 MR LORD: Ms Patrakova, please could you give his Lordship

6 your full name and address.

7 A. My name is Natalya Yurievna Patrakova, I live in

8 St Petersburg, Morskaya Embankment, 35/6, apartment 64.

9 Q. Thank you. Ms Patrakova, could you be shown a copy of

10 the B bundle, please, where your witness statement is to

11 be found? If you could be shown, please, divider 10,

12 and in particular {B2/10/6}, please. Do you have that

13 page, Ms Patrakova?

14 A. Yes, I do.

15 Q. And it looks as if that’s a witness statement that you

16 have given in connection with these court proceedings;

17 is that right?

18 A. Yes.

19 Q. And if you could please just turn on in the bundle and

20 turn to {B2/10/8}, you ought to find a page containing

21 your signature and the date of 25 August 2015.

22 A. Yes, I remember signing this document as of that date.

23 Q. Ms Patrakova, have you read that witness statement

24 recently?

25 A. Yes, I have had that opportunity.

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Arkhangelsky [Master]

81 :1 Q. And can you confirm to his Lordship on oath today that
2 the contents are true to the best of your information

3 and belief?

4 A. Yes, I can confirm that to the best of my information

5 and belief the contents of my witness statement are

6 true.

7 MR LORD: Thank you.
8 Cross-examination by MR STROILOV
9 MR STROILOV: Good afternoon, Ms Patrakova. Where in

10 St Petersburg was the office of Oslo Marine Group?

11 A. I’m not aware of the exact location.

12 Q. You say in your evidence that you travelled there by

13 car, haven’t you?

14 A. Correct.

15 Q. And that was from the office of the Bank, wasn’t it?

16 A. Yes, so far as I can recall.

17 Q. So how long —

18 A. I used a car to get there.

19 Q. How long was the drive?

20 A. I am afraid I do not recall that exactly.

21 Q. I think you said that the car was — so far as you

22 remember, the car was sent for you by Mr Arkhangelsky,

23 wasn’t it?

24 A. I believe that that was the case but, again, I am afraid

25 with the passage of time I no longer recall exactly.

82 :1 Q. Do you remember anything about that car, what kind of
2 car was that?

3 A. I do recall that — well, it was definitely not an HGV,

4 not a Jeep. It was just a plain car.

5 Q. Right, so do you recall about what time during that day

6 did you arrive to Oslo Marine Group office?

7 A. I am afraid I do not recall this exactly but, again, as

8 I was preparing for this evidence, I believe that this

9 was some time after the lunch break, in the afternoon,

10 because I do recall that I had been able to do some work

11 in the Bank before I left. It was definitely not early

12 in the morning.

13 Q. Right, and when you say «after lunch break», about what

14 time was the lunch break?

15 A. Well, I’m not saying that it was exactly after the lunch

16 break. What I do recall is that this was not

17 immediately after I arrived at work.

18 Q. No. I am sorry. What I mean is, about what time did

19 you have lunch break at work, around that time?

20 A. Well, that depended on the amount of urgent work that

21 needed to be transacted. There was no specific time

22 slot.

23 Q. Well, approximately?

24 A. Well, I would say between 1.00 and 2.00. It was not

25 longer than one hour, but the time it started changed

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Arkhangelsky [Master]

83 :1 depending on the circumstances.
2 Q. Right. Can you describe the building in which OMG

3 office was located?

4 A. I do not recall any details, I am afraid.

5 Q. Well, generally speaking, was it a huge skyscraper or

6 was it a small hut? Generally speaking, anything you

7 remember about the building?

8 A. Well, I do not have a very good recollection of this,

9 and I do not recall, actually, the moment when I entered

10 the building.

11 Q. Right. Just to try and refresh your recollection, did

12 you sign in at the reception?

13 A. I do not recall signing in. I do remember sitting on

14 a sofa whilst waiting.

15 Q. Was the whole building belonging to OMG, or was it only

16 a part of the building that was the OMG office?

17 A. Again, I’m not sure I can assist you on that. I only

18 remember the room. It was definitely an office, but

19 apart from that, I do not recall much.

20 Q. Perhaps you recall anything odd about the door plate?

21 A. No, unfortunately I have no recollection of that.

22 Q. Did anyone accompany you as you were being taken to near

23 Mr Arkhangelsky’s office?

24 A. Yes, I do recall being accompanied by someone, and

25 I remember it was a man, but, again, apart from that,

84 :1 I have no recollection.
2 Q. You said you remember sitting on a sofa in that room;

3 can you describe that room and that sofa? So far as you

4 remember. We appreciate a lot of time passed, but what

5 you remember, please try call back and tell his

6 Lordship.

7 A. Well, as a matter of fact I have attempted to recall the

8 various details, but I am afraid I am unable to provide

9 a clear description of the building, of the room.

10 Q. Do you remember what colour or colours were the walls in

11 that room?

12 A. No, I do not recall that.

13 Q. Then do you recall at some point Mr Arkhangelsky coming

14 to meet you? I think you describe that in your witness

15 statement, don’t you?

16 A. I do not recall the sequence of events, whether I was

17 already there and then he emerged from the room, or he

18 came out first and then I joined him, that I do not

19 remember.

20 Q. With my Lord’s permission, Ms Patrakova, if you could

21 turn around and look at the man you see on the screen

22 behind you. Do you recognise this man?

23 A. Well, he does look like that man, but he — I’m sure he

24 has changed a lot.

25 Q. Right, and I think you — one detail you said you do

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Arkhangelsky [Master]

85 :1 remember, very helpfully, is that the documents you
2 brought to him were in this plastic file; is that

3 correct? You remember that clearly?

4 A. I do not recall exactly, but I would not be surprised if

5 that was actually the case.

6 Q. Right. So can you just, again, roughly, and we

7 appreciate a lot of time has passed, roughly how many

8 documents were there?

9 A. Again, I can’t say, but I recall that it was not just

10 one document. Perhaps there were several copies of

11 the same document. There were several documents.

12 Q. Some of these documents had more than one page; is that

13 correct?

14 A. Yes.

15 Q. And was each document stapled?

16 A. As far as I recall, that was the case.

17 Q. So did you give Mr Arkhangelsky the entire plastic file

18 just for him to go through it and sign, or did you go

19 document by document?

20 A. I do not recall exactly the way I did it, but most

21 likely I have given all of the documents to him, but

22 I cannot now assert it.

23 Q. And then, essentially, you looked at the documents while

24 you say he was signing it?

25 A. Prior to giving them to him, do you mean? Could you

86 :1 please specify?
2 Q. Well, I think you said that you saw him sign the

3 document. So I just wonder what you mean by that. Were

4 you looking at the document as he was signing it?

5 A. Yes. I saw him signing it, because I had to make sure

6 that he is putting his signature to every page, not

7 missing a single page. This is very important when

8 signing an agreement, and that’s why I was attentively

9 watching.

10 Q. Right, so you saw him turn the pages and sign these

11 pages one after another?

12 A. Possibly it was even me paging through, turning the

13 pages.

14 Q. Is it possible that, in fact, you had various documents

15 loose in your plastic file, and you were just giving

16 them to him one page after another, rather than document

17 by document; is that possible?

18 A. No, I don’t think that’s what happened. It’s not my

19 habit to do it like that.

20 Q. Right. Let me explain why I was asking the last

21 question. The handwriting forensic experts have means

22 to establish with some degree of precision, as any

23 forensic evidence goes, whether a document was signed

24 while pages were in a pile, one on another, so that you

25 have — you know, for instance, you sign this document

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Arkhangelsky [Master]

87 :1 and then there is an imprint on that on the next page.
2 So you would expect, wouldn’t you, the loan

3 agreement which you say Mr Arkhangelsky signed in your

4 presence, to have this kind of imprint on every next

5 page, wouldn’t you?

6 A. I would not be able to assert, because I do not recall

7 the exact detail. I could surmise that that, most

8 likely, was the case. Yes.

9 Q. Yes. Ms Patrakova, perhaps I will read to you, in case

10 you can add any explanation. I am afraid I will be

11 corrected if I am wrong, I don’t think we have a Russian

12 version of that, so I will just read it to you in

13 English and then the translators will translate.

14 If we could, please, have document {E1/2/16}. So

15 that is an extract from the report of the forensic

16 handwriting expert instructed by the Bank, and at the

17 top two paragraphs it says this:

18 «Impressions of handwriting may be left on

19 a document as a result of writing on another document

20 which at the time of writing was overlying the first

21 one. These impressions are rarely visible to the naked

22 eye and need to be detected using specialised equipment

23 and techniques. I examined the original documents [such

24 and such] using the technique of Electrostatic

25 Detection… (document C2 is a copy and document C22

88 :1 a multi-page document and, therefore, I have not
2 examined these in the same manner).

3 «On document A14 I found impressions of

4 the Arkhangelsky signature on document A15. On

5 documents A13, A15, C1 and C21 I found impressions of

6 signatures which are clearly similar to the Arkhangelsky

7 signatures on this group of documents but which lack

8 sufficient detail for the individual signatures to be

9 identified. My findings indicate that some of

10 the Group 3 signatures may have been signed one after

11 another in a pile. That said, there are no similar

12 impressions found on the Loan Agreement A23.»

13 I am sorry, I am afraid I have wasted my time.

14 That’s a bad point.

15 MR LORD: It’s not the same agreement, Mr Stroilov.

16 MR STROILOV: I am sorry, my Lord.

17 My Lord, I think I have to ask for a 10-minute break

18 at this point, and I do apologise to Ms Patrakova.

19 MR ARKHANGELSKY: Your Lordship, can I just ask a small

20 question?

21 MR STROILOV: I don’t think so, no.

22 MR ARKHANGELSKY: No, no, I want you to change line 4 in the

23 [draft] transcript, page 86 because it is not correct

24 written, so instead of «silent», it should be «signed».

25 Line 4, page 86. It is an important change. Line 4,

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Arkhangelsky [Master]

89 :1 page 86.
2 MR JUSTICE HILDYARD: Very well, I am sure it will be done.

3 MR ARKHANGELSKY: It should be «signing».

4 MR JUSTICE HILDYARD: Yes, thank you. 10 minutes.

5 (2.37 pm)
6 (A short break)
7 (2.50 pm)

8 MR STROILOV: May it please your Lordship.

9 Mrs Patrakova, I put it to you that what you have

10 told us cannot be true. OMG office was located in the

11 port area of St Petersburg, near the sea port, and that

12 was a very tall building, one in the whole area. The

13 tallest building among very small buildings, and that

14 should have caught your eye.

15 A. I do not recall such a thing.

16 Q. Now, I put it to you that there are only two types of

17 car which Mr Arkhangelsky could have had at his disposal

18 and could have sent for someone to bring him documents.

19 One of them was a very characteristic green Ford Focus

20 with a clearly visible OMG logo on it. Were you

21 travelling by this kind of car?

22 A. I do not recall what the car was.

23 Q. Well, I think you said that, according to your

24 recollection, it was quite an ordinary car. Are you

25 sure that is your evidence?

90 :1 A. Usually with regard to the size of the car, this is what
2 I meant; that is, as far as I remember, it was a car,

3 a personal car, but with regard to the colour or any

4 notable details, unfortunately I don’t remember

5 anything.

6 Q. Well, I think Mr Arkhangelsky’s personal car was

7 slightly different. It was really quite an impressive

8 luxury Mercedes. Were you travelling by a car of this

9 kind, by any chance?

10 A. I wouldn’t be able to say. Too much time has gone by.

11 It is difficult for me to remember any details in this

12 regard.

13 Q. There was a reception security area, which was the first

14 thing you would see when entering the building, and you

15 would have to sign in and be given a pass.

16 A. I do not recall this. I do not recall the way I entered

17 the building or how I left the building, or how the

18 building looked from the outside. I only recall the

19 details of me being inside, so some details of being

20 inside an office building.

21 Q. You must have had — if you were there, you would have

22 had possibly quite a difficulty finding the office: it

23 was on the second floor, only part of the second floor,

24 and by saying that, I mean Russian second floor, which

25 would have been called first floor in this country, and

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Arkhangelsky [Master]

91 :1 there was the door plate was rather confusing. It was
2 the same logo, but rather than «OMG», it said «Scan

3 Marine Consulting». Does that remind you of anything?

4 A. Unfortunately it did not remind me of anything. I only

5 believe that I was escorted to the office; I wasn’t

6 alone when I was walking to the office.

7 Q. Do you recall you said you waited on the sofa. What

8 colour was that sofa?

9 A. I don’t know. I do not remember.

10 Q. What was the size of the room?

11 A. I also would not be able to say. It wasn’t a small

12 room. I recall that it wasn’t a very small room. It

13 wasn’t a small premises. The premises were not small.

14 Perhaps when I was sitting on the sofa it was — there

15 were some partitions, that sort of things. Maybe it was

16 partitioned away from another premises in some way,

17 that’s the type of detail I recall.

18 Q. Now, were there other people with you in that room while

19 you were waiting?

20 A. I recall that I waited on the sofa, then I walked a few

21 steps. I wouldn’t be able to say exactly whether it was

22 to a next door room or just behind the sofa, I don’t

23 recall such details, but in the room where the document

24 was signed, there were other people there.

25 Q. So, in fact, it was a different room where the documents

92 :1 were signed and where you waited, these were two
2 different rooms, weren’t they?

3 A. I don’t know. Either they were visually partitioned, or

4 anyway, one could say these were two different rooms.

5 I do not recall exactly.

6 Q. I put it to you that the only sofa in the vicinity of

7 Mr Arkhangelsky’s working office was of a remarkable

8 bright green, almost poisonous colour; was it that sofa?

9 Does that ring any bells?

10 A. No, I do not recall the colour.

11 Q. Do you recall any internal investigation the Bank had

12 into these events?

13 A. No, I do not. I remember that the only contact was when

14 we signed the documents in the office, then I do not

15 recall being part of this case. Nothing — nothing

16 special. I can’t remember anything special.

17 Q. Well, don’t you recall being asked questions by the

18 security department of the Bank about this?

19 A. I remember I was called up by the security department

20 with regard to some matter, but whether the matter was

21 connected to Mr Arkhangelsky or not, this is not

22 something I would be able to say because I don’t recall.

23 Q. Were you questioned by the Russian police about these

24 matters?

25 A. No. No, I was not.

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93 :1 Q. Mrs Patrakova, I must put it to you that, I don’t know
2 how you were persuaded to give this evidence, and

3 whatever made you do it, but that story is a piece of

4 fiction.

5 A. In my evidence I endeavoured to render all the

6 recollections I had in this regard, and I did not add

7 anything extra thereto. Therefore, I disagree with you,

8 sir.

9 MR STROILOV: In conclusion, I would like to apologise on

10 behalf of Mr Arkhangelsky for having to drag you all the

11 way to London. We know your personal circumstances, we

12 are sorry about that, but your evidence is of some

13 significance in this case and it is important for the

14 court to find out the truth. Thank you.

15 MR LORD: Does your Lordship have any questions for the

16 witness?

17 MR JUSTICE HILDYARD: You have none?

18 MR LORD: I have none.

19 Questions by MR JUSTICE HILDYARD

20 MR JUSTICE HILDYARD: As you have come all this way,

21 Ms Patrakova, I have one or two questions for you.

22 What was your role in the Bank within the credit

23 department at this time, in 2007 or whenever it was?

24 A. I was in charge of individual loans, ie advancing loans

25 in different shapes and forms, personal loans, consumer

94 :1 loans, mortgage-secured personal loans, car loans, car
2 purchase loans, and credit cards, things like that.

3 MR JUSTICE HILDYARD: Presumably you knew from that

4 experience, and also from the fact that you were being

5 dragged away from your work to go in a car to obtain

6 a signature, that some reliance was being placed on you

7 to be able subsequently to be able to confirm that the

8 signature had been placed properly and in your presence;

9 did you appreciate that?

10 A. Yes, I did appreciate that. The Bank did explain to me

11 how important it was to make sure that this happened,

12 and that’s why I’m here.

13 MR JUSTICE HILDYARD: Because, with all respect to you,

14 I must say that your recollection is very thin in

15 respect of this event on which you were being relied on

16 to be able to confirm subsequently; do you wish to

17 comment on that at all?

18 A. That’s absolutely true. My recollection is very thin.

19 It is very difficult for me to recall the exact

20 chronology of events after so many years.

21 MR JUSTICE HILDYARD: While you were in the reception

22 room — and you were kept waiting for 20 or 25 minutes,

23 I think you tell us — did you just sit on the sofa or

24 did you ask for a drink or anything like that? Was

25 there a drinking fountain or anything like that?

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Arkhangelsky [Master]

95 :1 A. So far as I can recall I was just sitting there, and
2 possibly looking through the documents. That’s it.

3 I do not believe I did anything apart from that. I did

4 not have any drinks.

5 MR JUSTICE HILDYARD: Yes. That’s all the questioning

6 I have. Does anyone wish to ask anything further?

7 MR STROILOV: I think I have one question. I am afraid it’s

8 probably in the grey area. I don’t think I can ask

9 a question I simply forgot, but I think …

10 MR JUSTICE HILDYARD: Well, ask it anyway.

11 Further cross-examination by MR STROILOV

12 MR STROILOV: Yes, sorry, Ms Patrakova, I forgot to put it

13 to you. You couldn’t have read the documents where you

14 were sitting because the place where the sofa was was in

15 a rather dark corridor, there wasn’t enough light to

16 read the documents; what do you say to that?

17 A. Well, maybe I did not read those, but I went through the

18 documents, or at least I held them in my hands. Just to

19 answer your question, sir, I wanted to explain to his

20 Lordship what I was doing during that time, and that’s

21 why I answered the question the way I answered it.

22 MR STROILOV: Thank you.

23 MR JUSTICE HILDYARD: I think I have one further question.

24 I am sorry, Mr Lord.

25 MR LORD: No, no.

96 :1 Questions by MR JUSTICE HILDYARD
2 MR JUSTICE HILDYARD: I’m sorry to ask you this: beyond

3 making arrangements for you to come here, and no doubt

4 paying for them, you have not been employed by this Bank

5 for some five or six years now; is that right?

6 A. That is correct.

7 MR JUSTICE HILDYARD: I can take it, can I, that there are

8 no arrangements between you and the Bank with respect to

9 your giving of evidence except for the arrangements for

10 your travel?

11 A. I am not sure I understood your question, my Lord.

12 MR JUSTICE HILDYARD: In addition to asking you to give

13 evidence — and it is very good of you to attend — have

14 they paid you, or suggested that they will make any

15 arrangements for you in that regard?

16 A. No.

17 MR JUSTICE HILDYARD: No.

18 A. No, I was not offered or given any money.

19 MR JUSTICE HILDYARD: Thank you very much for attending, and

20 I hope you get back today to your child or children.

21 MR LORD: Might this witness be released, my Lord, please?

22 MR JUSTICE HILDYARD: Yes.

23 MR LORD: Subject to the photographic record, which I must

24 say has slipped my mind.

25 MR JUSTICE HILDYARD: Yes, I can see, someone can have

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Arkhangelsky [Master]

97 :1 an iPad photograph or some such.
2 Thank you very much, you are free to go and to

3 return home. Thank you.

4 (The witness withdrew)
5 Housekeeping
6 MR LORD: My Lord, it is probably sensible to do some

7 housekeeping now.

8 MR JUSTICE HILDYARD: What are we going to do about

9 Ms Shabalina?

10 MR LORD: My Lord, she is here and she can be called. The

11 estimate was half a day. I am going on estimates that

12 I am given, and doing the best that I can. I have

13 a timetable that I put this morning, I put at lunchtime,

14 which is in my respectful submission unimpeachable in

15 meeting all concerns and observations yesterday.

16 MR JUSTICE HILDYARD: All I am asking is as she is here and

17 as Mr Stroilov wanted to get her over, no doubt so he

18 can stay in Cambridge or whatever it is to do his prep

19 tomorrow, if she can be brought in and completed, then

20 that seems orderly.

21 MR LORD: It does, my Lord. What I am only flagging for

22 your Lordship is if the estimate was even vaguely right

23 we won’t finish her today, we have something — when

24 I say housekeeping, there are one or two points that are

25 arguably more significant than housekeeping, and I am

98 :1 anxious that we resolve those without everyone getting
2 perhaps rather weary because of the hour. Housekeeping

3 tends to be done more effectively if it is not done at

4 4.30 or 4.45, at the end of a long day.

5 MR JUSTICE HILDYARD: How long are you going to be with

6 Ms Shabalina?

7 MR STROILOV: My Lord, sometimes it really depends on the

8 witnesses, I am learning.

9 MR JUSTICE HILDYARD: In your worst dreams?

10 MR STROILOV: In the best case scenario, I think it can be

11 over in an hour, but that rather depends.

12 MR JUSTICE HILDYARD: And if you were being gloomy, how long

13 would you tell me? If I was saying that there would

14 come a time when I would simply walk out, how long would

15 you tell me?

16 MR STROILOV: Well, on the safe side? I think on the safe

17 side I would still say half a day on that.

18 MR LORD: My Lord, would it be sensible to start?

19 A compromise would be to crack on now but at 4.00 we

20 really must resolve this issue that’s been raised today.

21 MR JUSTICE HILDYARD: About the Bank?

22 MR LORD: I’m very troubled by it. I pressed for some

23 details from Mr Stroilov in the intermission, I’ve had

24 no details and, in fact, the allegation seems to be that

25 Bank people have had a hand in this. So it is very

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Arkhangelsky [Master]

99 :1 serious, it needs clearing away, and it can’t really be
2 allowed — I am concerned that if we rise today and

3 Mr Stroilov goes back to Cambridge, we are going to

4 lose —

5 MR ARKHANGELSKY: I am sorry, your Lordship, I just got

6 a letter from my lawyer, I just got a letter from my

7 French lawyer, which I will pass you in a minute to your

8 clerk with the exact explanations of what is going on in

9 Société Générale. So she had a discussion and she has

10 written a letter addressed to you which will be on your

11 table in two to three minutes.

12 MR JUSTICE HILDYARD: Is Mr Stroilov aware of its content?

13 MR STROILOV: Not as yet, my Lord.

14 MR ARKHANGELSKY: Not yet.

15 MR STROILOV: I was about to say that I know that

16 Mr Arkhangelsky, just to free me, in order to try and

17 prepare for Ms Shabalina, he arranged for one of his

18 French lawyers to handle the matter, and there would be

19 either a letter or a witness statement explaining it for

20 your Lordship, but I haven’t actually seen the text as

21 yet.

22 I think another point I would like to make, with

23 your permission and with apologies, if Mrs Shabalina has

24 to be tomorrow, I am afraid I will help Mr Arkhangelsky

25 to prepare the notes, but I simply can’t do it tomorrow.

100 :1 Well, there is only so much one man can do. I don’t
2 think I can do it sensibly in any way.

3 So I would — if we are to spend time on —

4 MR LORD: Could we possibly — if we start Ms Shabalina, it

5 looks likes with a fair wind we might finish by 4.30.

6 If your Lordship would indulge us to maybe sit today

7 exceptionally a little later to transact the

8 housekeeping, bearing in mind that the fourth and fifth

9 day of this five-day week looks as though they are going

10 to be non-sitting days.

11 MR JUSTICE HILDYARD: Shall we do that, then? We will start

12 with Ms Shabalina. At 4.30 — and this is on the

13 premise that if you have not finished by 4.30 — and

14 your estimate is that you will — Mr Lord will not take

15 objection to the remainder of her cross-examination

16 being undertaken by Mr Arkhangelsky?

17 MR LORD: Yes, my Lord, so long as he doesn’t cover the same

18 ground again. So long as he is covering proceedings and

19 the baton is passed rather than going round the track

20 again.

21 MR JUSTICE HILDYARD: Yes.

22 Well, Mr Arkhangelsky, I’m sure you agree that it

23 would not be right, if you have to take over from

24 Mr Stroilov, because we do not finish by 4.30 pm today

25 with the examination of Ms Shabalina, that you will then

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Arkhangelsky [Master]

101 :1 have to take up the reins of duty but you will not
2 trespass back over matters which have been addressed by

3 Mr Stroilov, unless of course there is some plain

4 omission which you wish to cover and can justify it as

5 such. Those are the ground rules; are you agreed with

6 them?

7 MR ARKHANGELSKY: Yes, I do. Yes, I agree.

8 MR STROILOV: I beg your pardon, one more point, my Lord, so

9 that you are aware.

10 I am afraid I will have — if we are to proceed now,

11 the only problem, I will have to hand to Mrs Shabalina

12 two documents which are not translated. There is not

13 much substance I want to rely on, and I hope the

14 substance will become clear from questions and answers.

15 MR JUSTICE HILDYARD: Are they short documents?

16 MR STROILOV: They are. One is two pages and another is one

17 page, and it is not quite necessary to read through

18 them.

19 MR JUSTICE HILDYARD: All right.

20 MR STROILOV: They are, my Lord — and I will give

21 disclosure references so it can be followed up.

22 MR JUSTICE HILDYARD: Very well. We will crack on, then.

23 We may have to have a transcript break at some point.

24 MR LORD: I understand, my Lord.

25 MR JUSTICE HILDYARD: Yes.

102 :1 MR LORD: Ms Shabalina, could you please come into the
2 witness box. My Lord, her statement is behind

3 divider 11. It may be in B2.

4 MRS EKATERINA VYACHESLAVOVNA SHABALINA (Affirmed)

5 (All questions and answers interpreted except where

6 otherwise indicated)
7 Examination-in-chief by MR LORD
8 MR LORD: Ms Shabalina, could you please give his Lordship

9 your full name and address, please.

10 A. Ekaterina Vyacheslavovna Shabalina and I reside in

11 St Petersburg, Lenina Street, number 8, apartment 16.

12 Q. Could Ms Shabalina please be shown her witness

13 statement, which is at {B2/11/9}.

14 Ms Shabalina, you have a hard copy of the statement

15 in front of you in the file if you want to find that.

16 The numbering is in the bottom right-hand side.

17 A. Yes.

18 Q. Can you confirm that that looks to be your witness

19 statement in connection with these proceedings?

20 A. Yes, this is my witness statement.

21 Q. If you could please turn to page {B2/11/16}, you ought

22 to see your signature dated 26 August 2015.

23 A. Yes, this is my signature.

24 Q. And have you read the contents of that witness statement

25 recently?

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Arkhangelsky [Master]

103 :1 A. Yes, I re-read my statement during the break.
2 Q. And can you confirm on oath to his Lordship today that

3 the contents are true to the best of your information

4 and belief?

5 A. I can confirm that everything set out in my witness

6 statement is true.

7 MR LORD: Thank you, Ms Shabalina. Could you wait there?

8 Mr Stroilov will ask you some questions.
9 Cross-examination by MR STROILOV
10 MR STROILOV: Good afternoon, Mrs Shabalina. I’m sorry, is

11 it Ms or Mrs Shabalina?

12 A. Mrs.

13 Q. Mrs Shabalina, if we could have on the screen

14 {D34/537/1}, and on the other screen page 2 of the same

15 document {D34/537/2}. Mrs Shabalina, do you know of

16 a company called Renord-Invest?

17 A. Yes, I do.

18 Q. And what is that company?

19 A. Renord-Invest is one of the companies that work together

20 with some Bank clients with respect to the preparation

21 of investment projects in the event that the borrower,

22 himself or herself, was not in a position to properly

23 draw up an investment project in a manner and within the

24 time frame that both himself and the Bank would be happy

25 with in order to make sure that the loan application

104 :1 could be processed on time.
2 Q. And I understand that Bank of St Petersburg was working

3 rather closely with Renord-Invest; is that your

4 understanding?

5 A. Well, I am not in a position to assess the extent of

6 this cooperation. I have some history of dealings with

7 Renord-Invest. Well, we worked with them on three

8 occasions throughout my tenure. At the end of the day

9 out of all the projects that had been drawn up, I only

10 provided loans to two of those.

11 Q. To two of the clients who used the services of

12 Renord-Invest for consultancy; is that what you are

13 saying?

14 A. Could you be more specific, please? These were not

15 advisory or consultancy services. This was services

16 with respect to the drawing up of an investment project.

17 This is important for me. So our branch did provide

18 loans to two projects that had been drawn up with the

19 assistance of Renord-Invest.

20 Q. So just to be clear as to what your evidence is, were

21 these loans to Renord-Invest or any of their

22 subsidiaries, or were they to third parties?

23 A. Those were definitely loans advanced to third parties.

24 So those borrowers were our clients, and they came to us

25 asking for assistance in writing up those business

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105 :1 plans, and as a result of those business plans having
2 been drawn up, loans were provided to them.

3 MR JUSTICE HILDYARD: So those companies were unconnected

4 with the Bank and unconnected with Renord-Invest so far

5 as you were aware?

6 A. Correct. Those clients were totally unrelated to either

7 the Bank or Renord-Invest.

8 MR STROILOV: Now, do you recall ever suggesting, or that

9 the Bank ever suggested to Mr Arkhangelsky, that he uses

10 the services of Renord-Invest to prepare his business

11 plans?

12 A. That is quite possible, quite likely. I am not sure

13 I can recall all the circumstances surrounding this, but

14 most likely that had to do with an investment loan,

15 which Mr Arkhangelsky presumably sought to obtain from

16 the Bank.

17 We may have recommended that company in the event

18 that the investment project or the business plan that

19 the client had put in place was either not available at

20 all, or we were not happy with the form in which it had

21 been drawn up.

22 Q. Right, because the e-mail you see on the screen here,

23 that is, as you can see, it is an e-mail from

24 Mr Arkhangelsky to you and to Mr Belykh. Then if we

25 could scroll down respectively to {D34/537/3} on one

106 :1 screen and {D34/537/15} on the other. That is the
2 attachment to that e-mail, and that is a proposed

3 contract for consultancy services from Renord.

4 So what this suggests to me is that the Bank advised

5 Mr Arkhangelsky to use consultancy services of

6 Renord-Invest. Mr Arkhangelsky found the price to be

7 too high, and so he is coming back to you, drawing your

8 attention to the fact that the price is too high. Do

9 you recall anything along these lines?

10 A. Yes, my Lord, I do recall this e-mail. It’s true that

11 this did happen, this did take place. Mr Arkhangelsky

12 totally disagreed with the price that was being offered

13 for those services. I am not in a position to comment

14 with respect to what my position was, but because I —

15 judging from the fact that I recall this event and this

16 e-mail, I also thought that the price was sort of on the

17 high side.

18 I may be wrong, but that may well have been the

19 reason that Mr Arkhangelsky did not use the services of

20 that company at the end of the day and he wrote the

21 business plan himself. Again, I may be wrong. I don’t

22 remember which investment project this was, and what was

23 the investment project with respect to which we

24 recommended Renord-Invest.

25 Mind you, there were several advisory companies that

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Arkhangelsky [Master]

107 :1 were accredited with the Bank, this was not the only
2 one. Those were the companies that the Bank believed

3 were able to satisfy the Bank’s requirements in terms of

4 writing and drawing up business plans.

5 But, so far as I can recall, Mr Arkhangelsky always

6 did this on his own. I mean, in terms of preparing loan

7 documentation, he usually did it on his own.

8 Q. So are you saying that there was some kind of a list of

9 consultancy companies accredited, or associated with the

10 Bank which you could recommend to clients?

11 A. Now, if you insist on using the term «accredited», yes,

12 that was the case: the Bank did have a list of

13 accredited companies, amongst other things, those who

14 were accredited and recognised as companies that could

15 assist in drawing up business plans. This did not

16 include only Renord-Invest. The Bank usually tried to

17 use structurers and firms that the Bank had trust and

18 confidence in.

19 Q. Right. If I may just, for completeness, if I could —

20 I am afraid it is only in English, but I can read to you

21 what Mr Arkhangelsky says about this matter in his 19th

22 witness statement, so if we could, please, have

23 {C1/9/4}. What he says in paragraph 17 of this witness

24 statement:

25 «As I explain in paragraph 173 of my 16th statement,

108 :1 the idea of engaging Renord to develop the Group’s
2 business plans was imposed on us by the Bank. However,

3 we soon discovered that the proposed ‘consultancy’ was

4 extremely expensive and completely uncommercial.

5 Mr Smirnov and his colleagues did not appear to be

6 competent or hard-working enough to develop adequate

7 business plans for the group, but instead dropped heavy

8 hints that, if only we pay their sky-high fees, the Bank

9 would inevitably finance the project.»

10 Do you have any comments on that?

11 A. Well, I would be hard put to comment on what

12 Mr Arkhangelsky is writing or what his perception was,

13 and I’m not sure I can offer any comment with respect to

14 the level of qualification of Mr Smirnov and his team,

15 particularly because at the end of the day, I did not

16 see any results or any outcome, or any deliverables

17 being produced. At the end of the day the

18 Vyborg Shipping Company did receive a loan, even though

19 they had not entered into any contract with

20 Renord-Invest, but I think this is the best possible

21 confirmation that there was no duress applied by the

22 Bank, because otherwise it would have made absolutely no

23 sense for the Bank to process this loan in the absence

24 of a contract with Renord-Invest.

25 Q. Right. Thank you.

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109 :1 Now, I would like to show you a document, which I am
2 afraid is only available in the Russian for this one,

3 but I will do what I can to really discuss it with you

4 so that my Lord understands what it is. For the record,

5 that is document J/37 in the claimants’ disclosure, and

6 it was kindly arranged for me by the claimants’

7 solicitors.

8 Is my learned friend comfortable with — well,

9 I only have three copies, so if I could pass — I think

10 I can just pass one to the witness, and I don’t think

11 your Lordship will benefit much from looking at the

12 Russian copy, but I can pass one to the claimants or to

13 the — probably to the translators is the best idea.

14 MR JUSTICE HILDYARD: Yes. At some point these documents’

15 cross-reference to the transcript to, in effect, provide

16 the translation must be arranged.

17 MR STROILOV: Yes. So, Mrs Shabalina, you see your

18 signature at the top, so you approved this document,

19 didn’t you?

20 A. Yes. I approved the result of work done by my

21 employees.

22 Q. Yes, well, can you explain in your own words what this

23 document is and what it says?

24 A. This is a document called «An act of checking a pledge

25 provided under a loan». With regards to a procedure of

110 :1 monitoring the loans extended, the crediting department
2 of the Bank had to carry out the quarterly monitoring of

3 the financial state of the borrower, and I do not recall

4 the exact frequency, but also I think it was quarterly

5 checking of safety of the assets pledged, of

6 the property pledged, and for that the employees of

7 the Bank are the roles that would be a credit inspector,

8 a leading credit inspector, monitoring the loan, and

9 a security officer would go on site to look at the

10 subject of pledge, the collateral and, should any

11 recalculation were necessary, including the

12 recalculation.

13 And in this case it was talking about immovable

14 property, so we went on site, registered that the site

15 was still there, the object was there, and this act was

16 drawn to confirm the same.

17 Q. And that relates to the Onega Terminal, doesn’t it?

18 From looking at the address. So that says …

19 Perhaps you could read out, if you don’t mind, the

20 first paragraph, so that the translators can translate.

21 A. «We, the representatives of Investrbank branch, OJSC

22 Bank St Petersburg, the leading expert with regard to

23 branches of the security directorate MV Kiselyov and the

24 leading specialist of the credit department, Yashkina

25 VG, 07.02.08, in the presence of representatives of OJSC

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111 :1 PetroLes and OJSC Insurance Company Scandinavia
located
2 at St Petersburg Ugolnaya Gavani Elevatornaya

3 Ploschadka, house 14, letter A, house 1, have checked

4 the immovable property objects, land, empty premises,

5 passed over to the Bank St Petersburg as a pledge under

6 the loan to OJSC PetroLes number 3500-07-00352 dated

7 09.03.2007. During the check the following documents

8 were used: balance sheet as of 01.10.07; ownership

9 certificates, and sale and purchase agreements.»

10 Q. Thank you very much. I’m sorry to exploit you for this.

11 Now, Mrs Shabalina, am I right in understanding that

12 this involved people who signed this document going

13 physically to Onega Terminal to see the property?

14 A. In my opinion, yes.

15 Q. So as you can see, it is duly signed by Mr Kiselyov,

16 Mrs Blinova, Mr Shevelev as the director general of

17 PetroLes, Mr Arkhangelsky and then Mrs Borisova and

18 Mr Prokhor.

19 Do you have any reason to believe these people

20 didn’t do their job properly?

21 A. I think that I had no reasons at that point in time,

22 everything was done properly, I thought — I had no

23 reason to doubt that the job was done properly and,

24 therefore, the document was approved.

25 MR LORD: My Lord, sorry to …

112 :1 I have sort of had to reserve my position on
2 a document that has been put to a witness which is not

3 on the trial bundle at all, and is only in Russian, and

4 where I am going to be in some difficulty re-examining,

5 for rather obvious reasons. There is no translation

6 provided by Mr Stroilov, and, worse still, this appears

7 to be a document that concerns Ms Blinova who has come

8 and gone without the document being put to her.

9 MR STROILOV: That’s true, just for the …

10 MR LORD: I’m not going to make any more of it now, but in

11 the housekeeping time I will address your Lordship on

12 the unsatisfactory nature of having documents that are

13 not signalled enough ahead of time so we can, at the

14 very least, do a machine translation or something.

15 I will see if we can do that this afternoon while we

16 sit, but I think I must reserve my position in those

17 circumstances.

18 MR JUSTICE HILDYARD: To whom is the document addressed? Is

19 it not signed by this witness at all, or has this

20 witness got nothing to do with it?

21 MR LORD: I don’t know.

22 MR STROILOV: I think Mrs Shabalina has said that she

23 approved it, and you see her signature at the top.

24 MR JUSTICE HILDYARD: That’s what I understood, yes.

25 MR LORD: And then Ms Blinova is one of the —

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113 :1 MR STROILOV: That’s right, and it is entirely my fault,
2 just oversight, I am afraid I identified it after

3 Ms Blinova left —

4 MR JUSTICE HILDYARD: Yes, but you are asking this witness

5 whether she has any reason to believe that anyone,

6 including Ms Blinova, didn’t do that which it is

7 recorded they did.

8 MR STROILOV: That’s right, and I’m not suggesting they did

9 anything else, and I do apologise —

10 MR JUSTICE HILDYARD: If you were going to suggest they

11 didn’t, you might have put it to Ms Blinova, but as you

12 are not suggesting any such thing, we are just looking

13 at this as — well, I am not sure why we are looking at

14 it, but it will become clear in due course.

15 MR LORD: That’s the point. Your Lordship has the point.

16 MR STROILOV: I’m grateful for that and I acknowledge that

17 it is right for my learned friend to express this

18 concern.

19 Now, if we could perhaps call on the screen

20 {D44/772.1/0.1} and on the other screen {D44/772.1/1},

21 that’s the Russian version of the same document.

22 I do apologise, the translation is not very helpful.

23 So, Mrs Shabalina, that’s another document you have

24 approved, isn’t it?

25 A. Yes.

114 :1 Q. I am afraid it is also signed by Mrs Blinova, so that
2 your Lordship is aware, that’s a matter against me.

3 But that is — correct me if I misunderstand,

4 I understand that while you were the director of

5 Investrbank, it was your duty to periodically reassess

6 the real estate pledge to the Bank?

7 A. No, this is absolutely not the case. There was a strict

8 regimentation in the Bank as to how to carry out

9 valuation of real estate. Only companies that were

10 accredited with the Bank could do that. They had to

11 have the relevant licences and had experience in working

12 in real estate market. The Bank worked with official

13 valuations which were proffered by these valuation

14 companies, and this document only signifies that we have

15 received the valuation, in this case from the company

16 called OJSC Lair, and further, in accordance with the

17 Bank’s credit policy, we have accepted a certain

18 discount to the market value of the object specified, of

19 the pledge object specified and, thus, we could not

20 revalue that pledge in any way, that collateral could

21 not be revalued by us. Only if there are some

22 additional circumstances, the Bank could compromise and

23 change the discount in the event that, for example, some

24 material market factors would change. Or if, for

25 example, the client was unhappy with the current market

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Bank St Petersburg v Vitaly Day 5

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115 :1 valuation, he could have contacted another company for
2 a revaluation. But not the Bank, nor the Bank employees

3 could not independently carry out valuations of real

4 estate.

5 Q. Well, you will see that the bottom paragraph of that

6 says — and I need to check whether the English version

7 is intelligible, just wait a second. (Pause).

8 Could we scroll down, slightly, the English version

9 {D44/772.1/0.2}. Could we scroll up again

10 {D44/772.1/0.1}.

11 I am sorry to be doing it again, Mrs Shabalina.

12 Could you read the bottom paragraph of this document?

13 A. «Taking into account the favourable location of this

14 site and satisfactory transport accessibility, one could

15 draw a conclusion that the estimated valuation of

16 the real estate as of 13.05.08 could only change towards

17 increasing it.»

18 Q. Thank you. This suggests to me that there was some

19 analysis of the market by your employees rather than by

20 the valuation company.

21 A. I would not be able to recall the circumstances that

22 made us draw this suggestion. Most likely we had to

23 rely on the same official valuation that was obtained,

24 and this comment, I could now speculate that the comment

25 was made because the discount proposed by Investrbank

116 :1 was outside the standard that the Bank had at that point
2 in time. As a rule we used a 30 per cent discount

3 against the market valuation of real estate, and in this

4 particular case, the discount is stated as

5 20.8 per cent, which is considerably less, and it looks

6 like still having relied on the opinion of the valuation

7 companies, this inscription signifies that there was

8 additional argument to have a higher coefficient to

9 the market and to the pledge.

10 Q. I think, just to understand how these documents work,

11 there are very — we may need to look at them or not.

12 I think there are very similar documents called in

13 the same way as verification of the fair price of

14 the property. There is one dated 22 June 2007. If we

15 could just briefly look at it at {D22/423/1}, and the

16 English version is in the same tab, but it is

17 {D22/423/0.1}.

18 So, again, this is a similar document of an earlier

19 date, again approved by you, and again giving some

20 figures for the value of the pledge as compared to

21 the value of the loan, and making the same suggestion as

22 you have read to us before, very kindly, that the value

23 is only likely to grow.

24 Then there is one more document of the same kind,

25 dated 21 December, and that’s — would you like to look

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

117 :1 at it, and perhaps, let’s just for the sake of good
2 order {D32/512/1}. The English version is in the same

3 tab but the page is {D32/512/0.1}, and that is, so far

4 as I can see, it is practically identical with the

5 others ones but dated 21 December 2007.

6 Mrs Shabalina, what I am saying is that this

7 suggests some periodic monitoring of the market value by

8 the Bank; was that done?

9 A. One second. With your kind permission, my Lord, I will

10 have a look at the documents, because I see them for the

11 first time.

12 Q. I beg your pardon. Of course, take your time. (Pause)

13 A. I am prepared to answer your question, sir.

14 Q. Basically what I am asking you about is what do these

15 documents record? What did you do, you or your

16 employees at Investrbank, which led to this kind of

17 document being composed?

18 A. My Lord, could I please draw your kind attention to

19 the fact that two documents in D32 and in D22 pertain to

20 this same real estate site, and it says in the documents

21 about the same value, both the valuation and the market

22 value, and the same discount with regard to the pledge.

23 In D44 we are discussing different property and,

24 accordingly, there is — a slightly different

25 coefficient is applied to the pledge.

118 :1 Moreover, they talk about different loan agreements
2 in D32 and in D22. We see the documents with regard to

3 credit agreement 3200-07-352, and 44, D44. That’s the

4 document with regard to collateral of 350.

5 Q. Thank you, and it is right of you to point this out, but

6 I am asking you a much more general question. What was

7 the procedure? What did your employees do to produce

8 a document of this kind? Was there any assessment of

9 the pledges? What did they do? What kind of work did

10 they perform to produce this?

11 A. Absolutely. It says in every document what the

12 valuation was that we relied on to approve the value of

13 the pledge for the property, the pledge value, and it

14 refers to that very valuation of that particular real

15 estate that was accepted under pledge for a specific

16 agreement. When there were two identical valuations

17 with regard to the same agreement with different dates,

18 that most likely means that we made some amendments in

19 the agreement itself, and accordingly we have finished

20 drawing up the full set of documents that would be

21 required for the loan file.

22 Q. Yes. I am afraid, again, we have got — really by the

23 time I have reached you we have really got a language

24 problem, so now I want to read to you an extract from

25 a witness statement which is only available in English

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

119 :1 and for it to be translated to you, Mrs Shabalina. If
2 we could go to {C1/5/4}. Now, I will come to

3 the document in a moment. I suppose I had better ask

4 you first: do you recall being interviewed in 2011 by

5 a journalist called Grigory Mikhailovich Pasko?

6 A. I did not give any interviews to Grigory Mikhailovich

7 Pasko, the journalist you mentioned. I recall some

8 conversation with a person who introduced himself as

9 a lawyer of Mr Arkhangelsky. He asked me several

10 questions over the phone, and I answered the questions

11 over the phone as well.

12 Q. Well, I don’t accept that. He didn’t introduce himself

13 as a lawyer, he introduced himself as a journalist and

14 gave his name.

15 Let me read what he says, Mrs Shabalina. That’s in

16 paragraph 12, as you will see, of this witness

17 statement. He says:

18 «I also interviewed, by telephone, Ekaterina

19 Shabalina, a retired employee of the Bank who had been

20 involved in the arrangement of loans to OMG companies.

21 Her comments were remarkably different from those of

22 Mrs Maylsheva. She explained that, before advancing the

23 loans, the Bank would arrange for a very careful

24 examination of pledged assets by valuers and lawyers.

25 It was inconceivable for the value of the assets to be

120 :1 exaggerated. Mrs Shabalina’s view was that the value of
2 the assets fell sharply during the 2008 global economic

3 crisis, as with other assets all over the world.

4 Mrs Shabalina thought that the Bank ‘lost its nerve’ and

5 demanded repayment of its loans as well as pressing for

6 criminal charges to be brought against Mr Arkhangelsky,

7 instead of negotiating a commercially sensible

8 solution.»

9 Do you recall saying that?

10 A. I recall this conversation, and one more time I shall

11 reiterate that I was not informed about the fact of me

12 talking with a journalist. This is definite. My

13 position was stated in a quite similar way, but not

14 quite correctly and, if necessary, I am prepared to

15 comment point by point.

16 Q. Yes, probably I should have read it to you more slowly.

17 Let me now read it to you point by point, so that there

18 is no mistake. So he says that you:

19 » … explained that, before advancing the loans,

20 the Bank would arrange for a very careful examination of

21 pledged assets by valuers and lawyers.»

22 Did you say that, or is that inaccurate?

23 A. Yes, and absolutely, that was the truth, and all the

24 documents that we looked at signified the same, and the

25 presence of valuation reports and the inspections of

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Arkhangelsky [Master]

121 :1 the pledges, all of that was done.
2 Q. Right. Moving on, he continues to say what he says you

3 said:

4 «It was inconceivable for the value of the assets to

5 be exaggerated.»

6 Do you agree with that?

7 A. I agree with the assertion that the value of the assets

8 at the moment of extending the loans reflected the

9 market situation.

10 Q. Now, then he says:

11 «Mrs Shabalina’s view was that the value of

12 the assets fell sharply during the 2008 global economic

13 crisis, as with other assets all over the world.»

14 Is that correct?

15 A. Except the words «all over the world», because

16 I wouldn’t be able to pass judgment on that. Certainly

17 in Russia in 2008 the value of real estate dropped by

18 many times over.

19 Q. And then he says:

20 «Mrs Shabalina thought that the Bank ‘lost its

21 nerve’ and demanded repayment of its loans as well as

22 pressing for criminal charges to be brought against

23 Mr Arkhangelsky, instead of negotiating a commercially

24 sensible solution.»

25 What is your comment on that?

122 :1 A. Since at the point of commencing the dispute between
2 Mr Arkhangelsky and the Bank, I hadn’t been working for

3 the Bank for almost a year, I had no reasons to judge

4 the reasons that made the Bank enforce the loans.

5 Nevertheless, in all the previous periods of my working

6 for the Bank, my position always was that until, you

7 know, we had to rely on a negotiation process when it is

8 still possible, and that is probably what I was trying

9 to communicate to Mr Pasko. His interpretation, in your

10 words, is not quite accurate, but the point of trying to

11 exhaust all the limits of opportunities of negotiation

12 processes, yes, it remains my position, it doesn’t rely

13 on some specific fact with regard to the Bank and

14 Mr Arkhangelsky’s relationship.

15 Q. Right. Thank you.

16 I would like to have a look at a document you

17 exhibit with your statement. That will be at

18 {D13/288/1}, and the Russian version is at the same tab

19 {D13/288/3}.

20 So that is an application for the loan to be given

21 to Onega, one of the OMG companies. The point I was

22 interested in, if you look at sections 24 and 25, you

23 can see that there is a guarantee by

24 Scandinavia Insurance Company’s offered, and if we could

25 scroll down the page in the English version, and in

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

123 :1 the Russian version as well {D13/288/2}, {D13/288/4}.
2 Then I think there is a guarantee offered by Scandinavia

3 Leasing Company, but I don’t see any personal guarantee

4 being offered. Have you read as far as to agree with

5 that?

6 A. Yes. There is no such entry in the loan application,

7 that’s true.

8 Q. So this suggests to me, if you are right in saying that

9 there were personal guarantees, there should be some

10 record of you or the Bank, at any rate, writing back to

11 Mr Arkhangelsky saying: well, we’re afraid your

12 application is not good enough. You have to add

13 a personal guarantee. Did that happen?

14 A. Definitely. The loan application is a wish, is

15 an expression of the client’s wish. It is his vision,

16 it’s the way he anticipates that the loan will be

17 extended, in which form and how it will be extended.

18 Now, in response to that, Investrbank, in this

19 particular instance, begins looking at the financial

20 situation, it analyses the proposed security, it writes

21 a report, which is drafted by the officer, then the

22 small credit committee looks into this, and then one of

23 the main requirements is a personal guarantee. It’s not

24 something that the client wishes to see happening. This

25 is what the requirement — what the Bank does require,

124 :1 therefore, in the application there is nothing to
2 the effect that he is happy to provide a personal

3 guarantee.

4 Having said that, the minutes of the MKK and BKK and

5 the management board are brought to the attention of

6 the client and then it is up to him to decide whether or

7 not he agrees with the decision made by the Bank bodies.

8 Terms and conditions, maturities sometimes changed

9 because the Bank was not happy with certain terms and

10 conditions, the security proposed, the amount sometimes

11 changed if the amount of security proposed fell short of

12 the amount sought. This is par for the course. This is

13 what happens all the time.

14 Q. Thank you. You don’t need to respond in such a detailed

15 way. I am conscious about the time.

16 What I wanted to ask you is that you are suggesting

17 that at some point you, or someone else in Investrbank,

18 would write to Mr Arkhangelsky to say: well, MKK minutes

19 or BKK minutes, your application has been refused, you

20 have to make a new one and offer a personal guarantee;

21 is that what would happen?

22 A. I am not sure I will be able to give you a short answer.

23 The short answer is: no, this did not take place.

24 Now, if you want me to go into the details, then

25 definitely those decisions were brought to the attention

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Bank St Petersburg v Vitaly Day 5

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125 :1 of the client by sending him the minutes, or sometimes
2 in the course of a face-to-face meeting with a client,

3 whether the changed conditions were changed. The Bank

4 never asked the client to change the actual application,

5 because there was no need to do that.

6 Q. Right. Well, I understand, Mrs Shabalina, that

7 basically this document you see on the screen, this is

8 one of the compulsory documents; that is to say in every

9 corporate loan file, we must find the document of

10 the same nature. Isn’t that right?

11 A. Yes. This is step one in any work that we did to

12 process a loan application.

13 Q. My Lord, I would like my learned friends and their

14 instructing solicitors to listen to what I say very

15 carefully, because I am practically sure I am correct,

16 but if I am incorrect, I would like to be corrected.

17 Mrs Shabalina, there are six corporate loan files

18 have been disclosed in these proceedings, and in those

19 files, only two loans are accompanied by a document of

20 this kind, by the loan application. The other four have

21 not been disclosed. Are you saying that unless

22 something extraordinary has happened, the Bank must have

23 them?

24 A. Well, I cannot confirm that without this kind of

25 document. We would not have been able to start work on

126 :1 the loan application but, as a general rule, this
2 document should have been available. It was part of

3 step one of any credit or loan dossier, or loan file.

4 Q. So but you are saying — and, again, so far as I could

5 ascertain from reading, I hope, a few thousand of

6 the documents disclosed in these proceedings — well, at

7 least looking through them, I shouldn’t use the word

8 «read» — so far as I could tell, I couldn’t find any

9 written message or any letter or e-mail or anything, the

10 Bank would say more or less expressly: sorry,

11 Mr Arkhangelsky, your application is refused because you

12 haven’t offered a personal guarantee as security.

13 So are you saying that is natural and that’s how it

14 should be?

15 A. My Lord, I’m not sure I understood the question. Could

16 Mr Stroilov please be more specific?

17 Q. I beg your pardon, it is entirely my fault, I am sure.

18 What I am suggesting, I think you said a moment ago

19 that if the loan application does not offer a personal

20 guarantee, you would inform the client that the Bank

21 wants a personal guarantee, and you say this is never

22 put in writing. It’s always done in some other form.

23 Is that correct?

24 A. Yes, this is brought to the attention of the client by

25 sending him a copy of the decision of the respective

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Bank St Petersburg v Vitaly Day 5

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127 :1 credit committee, MKK or BKK.
2 Q. And the decision would be that the loan must be refused

3 because the security offered by the client is

4 unsatisfactory; would that be the decision?

5 A. No, the decision will be to grant the application on

6 condition 1, 2, 3, 4, all the terms and conditions,

7 based on which the Bank would then be happy to grant the

8 request, or satisfy the application.

9 Q. Now, Mrs Shabalina, I think in your statement you

10 explain that at one point you had a conversation with

11 Mr Arkhangelsky explaining that he needs to provide

12 personal guarantees. You recall that part of your

13 evidence obviously, you have just said it, and I put it

14 to you that Mr Arkhangelsky has no recollection of that

15 conversation.

16 A. I do definitely recall my witness statement and I am

17 happy to confirm, yet again, that we did have this

18 conversation. We actually had a series of conversations

19 and every time Mr Arkhangelsky was asking me why this

20 was needed, and every time he received the same reply,

21 which was that unless this requirement is met, no loan

22 can be advanced and every time he made the positive

23 decision.

24 Q. I beg your pardon. It is my inefficiency. I am trying

25 to find the place in your statement I wanted to —

128 :1 MR JUSTICE HILDYARD: Paragraph 17. {B2/11/4}
2 MR STROILOV: Yes, I think in paragraph 17 of your witness

3 statement, if we could, please, have page {B2/11/4}.

4 Now, I don’t think you say that was on every occasion,

5 it sounds as if it happened only occasionally, and then

6 you say that:

7 «[He didn’t] negotiate particularly forcefully for

8 the Bank to abandon this requirement.»

9 But I think you have now suggested that he was

10 objecting to this every time.

11 A. Well, I did not use the term «object». What I meant was

12 that every time he tried to avoid entering into

13 a personal guarantee — again, I apologise for using

14 this term «every time». I mean, to the extent that

15 I can recall, and we discussed this matter on a number

16 of occasions.

17 Now, whether this applied to every single loan or

18 not, I’m not prepared to tell you as I sit here today,

19 but it did take place on a number of occasions.

20 Q. Right, Mrs Shabalina. What I put to you — no, I’m not

21 putting a positive case.

22 Did it happen at any stage that it was indicated to

23 you, in some form, from Mr Savelyev’s office, that you

24 should not — that you should put the personal

25 guarantees on your records for these loans, but if

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Arkhangelsky [Master]

129 :1 Mr Arkhangelsky doesn’t actually provide one, you should
2 turn a blind eye to this? Did that happen?

3 A. My Lord, can I ask Mr Stroilov to be more specific once

4 again. What period of time is he referring to?

5 Q. I’m terribly sorry. I am suggesting that this must have

6 happened at some point in 2006.

7 A. In 2006 very few people, apart from Investrbank, were

8 aware of this client or their existence. We were

9 working directly with that client and we did not receive

10 any instructions, either from Mr Savelyev’s office or

11 from any other offices, for that matter.

12 Q. Well, are you saying that in that period in time

13 Mr Arkhangelsky only dealt with you rather than with the

14 head office? Are you saying that?

15 A. It was a client who, for all practical purposes, worked

16 only with the branch, with our branch. And I do not

17 recall in 2006 — I do not recall anyone from the head

18 office dealing with him in 2006.

19 Q. Well, what about Mr Belykh?

20 A. I do not recall Mr Belykh taking any part in this

21 unfolding situation in any way.

22 Q. I think Mr Belykh says that he actually directed —

23 let’s look at what he exactly says. I think it is fair

24 to say that he says he put him in touch with you.

25 MR LORD: I think it is fair to the witness that the

130 :1 statements are not misquoted, and it should be shown,
2 {B1/6/2} and paragraph 6. It is quite wrong to

3 mischaracterise —

4 MR JUSTICE HILDYARD: Hold on, let’s …

5 MR LORD: {B1/6/2}.

6 MR STROILOV: Paragraph 9, I see what you are looking for.

7 MR LORD: Yes, but 6 …

8 MR STROILOV: If you could scroll down to the Russian

9 version, paragraph 9 there, if that’s not too complex

10 a task {B1/6/15}. My learned friend is quite right.

11 I have misquoted, for which I apologise.

12 If you could look at paragraph 9. {B1/6/3}. Don’t

13 bother to read further than that. Just paragraph 9. Is

14 that consistent with your recollection?

15 A. As I mentioned in my witness statement, I really do not

16 recall exactly who recommended Mr Arkhangelsky to me.

17 It may well have been Mr Belykh.

18 Q. Now, I think your witness statement also refers to

19 Mrs Arkhangelskaya at some point visiting Investrbank.

20 What I am suggesting to you, Mrs Shabalina, is that she

21 came there not to sign consent to a personal guarantee,

22 but for some other purpose which may have been a credit

23 card, or bank account, or transferring money from your

24 bank to another bank, possibly, but you are mistaken in

25 thinking it was a consent to a personal guarantee.

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Arkhangelsky [Master]

131 :1 A. Could you please specify the exact clause in my witness
2 statement that you are referring to, sir?

3 Q. I can, yes.

4 A. I have found this. It is in my paragraph 18. {B1/6/5}.

5 Q. Thank you very much. I’m sorry I couldn’t speed it up.

6 A. I did not attend while Mrs Arkhangelskaya was visiting

7 the Bank, so I cannot confirm that she signed that

8 consent form in my presence, but I believe that I do

9 recall that she came to the Bank precisely to sign off

10 on the consent form in the presence of the loan

11 department employees, because otherwise we would have

12 needed a notarised consent form signed by her. This is

13 what the Bank regulations provide for.

14 Q. Mrs Shabalina, it sounds from your evidence today, and

15 I think from your statement, it looks like really what

16 regulations provide for is all these followed in minute

17 detail. Are you saying this is how Investrbank worked?

18 A. Well, there are compromises in any work that a human

19 person may be doing, but not loan work, not banking

20 activities. We tried to draw up all the documents so

21 far as the loan documentation was concerned in the most

22 appropriate and formal way.

23 Q. Well, I don’t accept that. I don’t think I will set out

24 all the examples I want to rely on to rebut that.

25 I simply — I would appreciate some guidance, my Lord.

132 :1 I will invite you, in due course, to rely on the
2 inaccuracy of this statement in assessing this witness’s

3 credibility. Do I need to put all the backdating and

4 all these kind of matters to this witness, or can this

5 be …

6 MR JUSTICE HILDYARD: Well, you might want to ask

7 Mrs Shabalina whether she was ever aware of, or

8 personally permitted Mrs Arkhangelskaya to sign her

9 spousal consent at home rather than at the office.

10 A. I am not sure that I can say either yes or no in

11 answering your question, my Lord. It may have been the

12 case that some documents were handed over to

13 Mrs Arkhangelskaya for signature, but I have no

14 recollection of that.

15 MR STROILOV: My Lord, is that enough for that line?

16 MR JUSTICE HILDYARD: The principal things you have relied

17 on — and I must say that I am a bit hazy as to

18 the time — but the principal things you have relied on

19 are changes in the file F documents, I don’t know

20 whether you wish to ask about that —

21 MR STROILOV: Well that was after —

22 MR JUSTICE HILDYARD: — but that was afterwards, because

23 she left in 2008. And the question as to what appears

24 to be routine «backdating» of documents. If you wish to

25 ask about that, perhaps you should do so.

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Arkhangelsky [Master]

133 :1 MR STROILOV: Unless it is — unless you stop me, I will put
2 them in quite general terms.

3 I think there have been quite a number of documents

4 featured in these proceedings which seem to have

5 a seriously incorrect date on them; what do you say

6 about that? I mean documents coming from Investrbank.

7 MR JUSTICE HILDYARD: In particular documents purporting to

8 record decisions made on one date when, possibly, the

9 decision was not made until a subsequent date or,

10 alternatively, the document was made quite a lot later,

11 but was made to appear as if it had been made on

12 an earlier date. Those were the two examples, I think.

13 Were you aware of any of that?

14 A. My Lord, I am not sure I understand the purport of that

15 question. You see, the documents were processed

16 according to certain procedures. Not a single document,

17 with respect to Mr Arkhangelsky was within the remit of

18 the branch, and without the branch’s decision, no other

19 departments could have pitched in, so I am not sure

20 I can even visualise the situation that you are

21 referring to, sir.

22 MR STROILOV: Should I move on, my Lord? Is there

23 something …

24 MR JUSTICE HILDYARD: Well, I mean, I don’t know whether

25 this is a particularly good example because I am not

134 :1 sure when in 2008 this witness left, but paragraph 65 of
2 Ms Yashkina’s witness statement at {B1/7/13},

3 paragraph 65, refers to backdating of minutes of

4 relevant committees in quite general terms. I don’t

5 know whether that is a simple way of looking at things?

6 MR STROILOV: Yes, I think that’s right. Yes, my Lord,

7 thank you, and I can, I suppose, finish this line fairly

8 quickly, I see what you have in mind.

9 MR JUSTICE HILDYARD: Yes.

10 MR STROILOV: Would your Lordship have the reference?

11 MR JUSTICE HILDYARD: Yes, I’m sorry, {B1/7/13} at

12 paragraph 65 in the English version, and I should

13 imagine that is at {B1/7/35} in the Russian version. If

14 that will do, that will do. Otherwise you had better

15 give an example of what you say in order to …

16 MR STROILOV: No, I think that is all right, the way I will

17 put the question.

18 Have you read it, Mrs Shabalina?

19 A. Yes, I have read this. I have no comment to offer

20 because I officially resigned as director of Investrbank

21 in August 2008.

22 Q. That’s right. Well, what I am just trying to

23 understand: are you saying that this kind of thing never

24 happened in your times?

25 A. My Lord, my apologies, I have to clarify the question

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Arkhangelsky [Master]

135 :1 again. What did Mr Stroilov mean when he says «never
2 happened this kind of thing», what did he mean?

3 Q. Decisions backdated.

4 A. It might have happened as a technical drawing-up of

5 decisions; for example, if after the major credit

6 committee meetings a branch would have been able to

7 eliminate some material remarks and pass a decision on

8 the date of the meeting, I give it that that could have

9 happened.

10 Within the branch’s operations that would not be the

11 case because we did not have set dates for meetings. We

12 had the right to have the meetings on a daily basis, but

13 we had no need to do so.

14 MR STROILOV: I will move on.

15 MR JUSTICE HILDYARD: Mr Stroilov, I just notice that it is

16 4.30 pm.

17 MR STROILOV: I don’t know how long my learned friend and

18 you may need, my Lord. I think I won’t need longer than

19 five minutes.

20 MR JUSTICE HILDYARD: Five minutes, very good. Home

21 straight.

22 MR STROILOV: Mrs Shabalina, does the name Yulia Slavovna

23 Levitskaya tell you anything?

24 A. No, I cannot recall a person with such a name.

25 Q. Were you ever questioned by Russian police investigators

136 :1 about the Bank’s relations with Mr Arkhangelsky?
2 A. Yes. I was present at one of the interrogations, being

3 questioned by an investigator.

4 Q. Are you frightened of them?

5 A. No.

6 Q. I’m sorry to put it to you like that, Mrs Shabalina, but

7 it looks — it seems to me that your evidence is

8 influenced by fear.

9 A. I’ve got absolutely nothing to fear.

10 MR STROILOV: Thank you.

11 MR LORD: I don’t have any questions.

12 MR JUSTICE HILDYARD: Hold on. (Pause).

13 MR ARKHANGELSKY: Can I give one-minute instruction to

14 Mr Stroilov? Just if he can see his e-mail, please.

15 MR JUSTICE HILDYARD: Okay, yes.

16 MR ARKHANGELSKY: My instructions are in an e-mail to him.

17 MR STROILOV: I beg your pardon for this being done

18 publicly.

19 MR JUSTICE HILDYARD: That’s all right. I am sure you will

20 read it.

21 Questions by MR JUSTICE HILDYARD

22 MR JUSTICE HILDYARD: Mrs Shabalina, can I ask you to look

23 at paragraph 21 of your witness statement, please,

24 {B2/11/13}, {B2/11/5}. I don’t know if this will be

25 important, or even relevant, but I did not understand

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Arkhangelsky [Master]

137 :1 what you were telling me in paragraph 21 where you
2 explained what you suggest was the reason for LPK

3 Scandinavia ceasing to be a guarantor for the first

4 Onega loan. Could you have a look at what you have said

5 and see whether you can make it clearer for me? I do

6 apologise.

7 A. I will endeavour, my Lord. Within the norms of

8 the Central Bank, the standards applicable for groups of

9 companies, it is necessary to evaluate the related

10 entities of interrelated borrowers within the total

11 limit, the general limit, and in the event of this limit

12 exceeding a certain figure, then reserves need to be

13 accrued and, accordingly, the Bank’s financial status

14 would be worsened by that. LPK Scandinavia was not, as

15 I surmised, related by anything except the guarantee

16 with the group and the Onega loan, and therefore,

17 possibly we have made a decision to break off this only

18 mutual link in order to avoid calculating the joint

19 total limit for the group.

20 MR JUSTICE HILDYARD: But surely it is only to the Bank’s

21 advantage to have another guarantor, whether connected

22 or not?

23 A. Yes, in this case we have lowered the security for the

24 Onega loan, the security limit.

25 MR JUSTICE HILDYARD: And that was for regulatory reasons,

138 :1 was it?
2 A. Most likely, yes. Although I cannot assert it

3 unequivocally because too much time has gone by.

4 MR JUSTICE HILDYARD: Just a page or so back, can I ask you

5 quickly about paragraph 18 of your witness statement,

6 {B2/11/4} where you tell me that:

7 «It was the Bank’s policy, in accordance with the

8 laws of the Federation of Russia, to seek a spousal

9 consent when a personal guarantee was given.»

10 Were there any legal requirements relating to

11 spousal consents? I have in mind, for example, whether

12 the spouse had to be advised that they might need

13 separate legal advice, or some such.

14 A. No. Within Russian legislation, a guarantee of a person

15 which is married without spousal consent is illegal, is

16 not legal, and this is what the Bank was guided by when

17 demanding for married persons to always provide spousal

18 consent if they extend a personal guarantee. That is

19 not the Bank’s regulations, this is the Russian

20 legislation, and in the event of not providing the

21 consent of a spouse, that guarantee would not be

22 legitimate — would not be deemed legitimate.

23 MR JUSTICE HILDYARD: But I imagine that the regulations of

24 the Bank were designed to conform with the laws of

25 the Russian Federation to which you refer; yes?

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Arkhangelsky [Master]

139 :1 A. Absolutely, my Lord.
2 MR JUSTICE HILDYARD: Yes. Do the Bank’s regulations, or

3 did they at the relevant time, prescribe any formalities

4 as to the context in which the spousal consent would be

5 sought, in particular, did those regulations prescribe

6 that the spouse should be advised that he or she might

7 wish to take separate legal advice?

8 A. The Bank’s regulations did not encompass any

9 recommendations with regard to legal advice to any

10 persons signing agreements. That was their personal

11 right and responsibility on the part of the signatory.

12 MR JUSTICE HILDYARD: Did those regulations prescribe the

13 mode in which the consent should be supplied? Did it

14 have to be personally witnessed by a Bank official or

15 anybody else?

16 A. Yes, the regulations did exist and they prescribed

17 either witnessing by one of the credit officials or

18 notarised confirmation of the signature.

19 MR JUSTICE HILDYARD: Do you know whether those regulations

20 reflected a requirement of the law of the Russian

21 Federation?

22 A. I could only suppose the answer is yes.

23 MR JUSTICE HILDYARD: Yes. Well, so far as I am concerned,

24 those are my questions. Do they give rise to any

25 questions?

140 :1 MR LORD: My Lord, when I got to the housekeeping time,
2 I was going to show your Lordship we have uploaded the

3 policies that your Lordship wanted, including the

4 policies —

5 MR JUSTICE HILDYARD: Yes, I saw on my —

6 MR LORD: — and I apologise for not taking your Lordship to

7 it, I didn’t think it was necessarily going to come up

8 so soon. We have been trying to answer your Lordship’s

9 query last week about policies. There are some

10 documents on this.

11 MR JUSTICE HILDYARD: I am sorry.

12 MR LORD: I probably should have flagged it up sooner.

13 Could I just flag up the relevant spousal consent

14 entries, so your Lordship has those?

15 MR JUSTICE HILDYARD: Yes.

16 MR LORD: In Magnum {D12/262.1/0.16}. My Lord, I was hoping

17 to get some copies done so your Lordship has this and

18 has it as a ready reckoner rather than have to go —

19 MR JUSTICE HILDYARD: Yes, I’m sorry to take you by

20 surprise, it is just that this is the witness that gives

21 evidence as to the laws of the Federation (Handed).

22 Thank you.

23 MR LORD: Your Lordship will see the front sheet of that

24 bundle.

25 MR JUSTICE HILDYARD: Yes.

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Arkhangelsky [Master]

141 :1 MR LORD: We’ve tried to track down some additional
2 policies. Your Lordship asked about these, about the

3 policies and so on with lending.

4 MR JUSTICE HILDYARD: Mm.

5 MR LORD: And the index shows what was in force at what

6 point in time. So far as we can see, the spousal

7 consent entries are behind divider 3 at

8 {D12/262.1/0.16}. Not a reference that trips off the

9 tongue. I am sorry about that, my Lord.

10 MR JUSTICE HILDYARD: Has Mr Stroilov been supplied with

11 these?

12 MR LORD: No, he hasn’t. They have been uploaded, but

13 I wanted to get them translated and —

14 MR JUSTICE HILDYARD: Are they in the present Magnum system?

15 MR LORD: They are.

16 MR JUSTICE HILDYARD: So they were disclosed and they are

17 part of the trial bundle.

18 MR LORD: One of the policies — the policies have been

19 disclosed, yes, they have. They were disclosed,

20 I think —

21 MR JUSTICE HILDYARD: Which bit of this do you commend to

22 me?

23 MR LORD: Only halfway down:

24 «When providing a credit under the surety of an

25 individual.»

142 :1 MR JUSTICE HILDYARD: I see.
2 MR LORD: It is a short section, (a) and (b), then there is

3 an appendix, number 6, which is at the reference 0.30,

4 further on in this, which appears to be — I certainly

5 haven’t double-checked — but it is close to the form

6 that we see in the files.

7 Does your Lordship have the appendix number 6?

8 MR JUSTICE HILDYARD: Yes, thank you.

9 MR LORD: I need to check whether the Russian law evidence

10 is as it has been debated today.

11 MR JUSTICE HILDYARD: Well, this doesn’t take that forward,

12 but presently my understanding is that this witness

13 believes that these regulations reflect a requirement of

14 the laws of the Russian Federation, including,

15 I imagine, the form which you have taken me to. But

16 that may be right, it may be wrong.

17 MR LORD: We will check.

18 MR JUSTICE HILDYARD: I don’t mean any disrespect in that,

19 but you have simply told me what your belief was, not

20 that you could be sure of that.

21 MR LORD: Yes.

22 MR JUSTICE HILDYARD: Are there any other questions that

23 arise from my questioning? Mr Stroilov, are you content

24 that this witness be released, then?

25 MR STROILOV: I do, my Lord.

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

143 :1 MR JUSTICE HILDYARD: You are content with that?
2 MR STROILOV: Yes, I am.

3 MR JUSTICE HILDYARD: Thank you very much for your

4 attendance.

5 (The witness withdrew)
6 MR LORD: My Lord, I don’t know whether your Lordship thinks
7 the transcript writers would have a short break. I see
8 the time, and we obviously will have to move swiftly.
9 MR JUSTICE HILDYARD: Yes, you are quite right, I am sorry.
10 You must be exhausted.
11 What shall we say, how long would you like? Five
12 minutes. Do you have the e-mail that Mr Arkhangelsky
13 wanted you to see?
14 MR STROILOV: I have, my Lord, yes.
15 MR JUSTICE HILDYARD: Has everyone got the e-mail which
was
16 passed up to me from Nadejda Bidault?
17 MR STROILOV: Yes, indeed, my Lord.
18 MR JUSTICE HILDYARD: Addressing «To whom it may
19 concern …»
20 MR STROILOV: Yes, and that’s Mr Arkhangelsky’s French
21 lawyer.
22 MR JUSTICE HILDYARD: Mr Lord has that too?
23 MR LORD: I have a copy of it now.
24 MR JUSTICE HILDYARD: Thank you very much, five minutes.
25 (4.46 pm)
144 :1 (A short break)
2 (4.51 pm)
3 Housekeeping
4 MR LORD: My Lord, I see the hour. May I make this

5 suggestion: that Mr Stroilov wants time to get on with

6 his preparation, which is understandable, and we’ve

7 tried to bend the timetable to accommodate that to

8 a degree. It may be sensible for him to deal with some

9 timetabling which concerns him now, and to pick up this

10 matter about the money tomorrow with Mr Arkhangelsky,

11 who I don’t understand to be in any difficulty

12 attending, unless your Lordship wants to deal with it

13 all tonight.

14 It is just the face of this letter seems to beg more

15 questions than it answers, and your Lordship will

16 recollect at the beginning of today’s proceedings, what

17 was alleged — I will check the record, but I think what

18 was alleged was that my clients were somehow taking

19 steps to prevent the release of monies to finance

20 Mr Arkhangelsky’s Paris expenses. I stand to be

21 corrected, but that was how I understood this morning’s

22 allegation. It was repeated by Mr Stroilov when

23 I pressed him for details during the course of today,

24 and this is the letter that has come back.

25 Now, I need to make some submissions on this and

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

145 :1 what it entails. There are issues about the freezing
2 injunction, and there are issues about the asset base

3 and whether various things can or can’t be done in this

4 case, such as Mr Steadman, for example, or Mr Radley

5 coming along, because there are various points that

6 arise.

7 That can’t be done in five or ten minutes, and

8 I seem to have misunderstood the point from this

9 morning. This French lawyer’s letter seems to suggest

10 that Société Générale have said: hang on a minute, you

11 can’t take out €70,000 because of this freezing

12 injunction. That appears to be what is said there, that

13 is actually correct. No impropriety against Bank of St

14 Petersburg, that should be entirely retracted, but there

15 is a further question of how monies are to be released

16 and what’s been going on — really what’s been going on

17 in terms of the freezing order and why it was thought

18 appropriate to take out €70,000 in this way without

19 actually contacting the Bank of St Petersburg in

20 the light of the existing freezing injunction, but those

21 are quite big points, and the bottom line may be for

22 your Lordship: can we release the monies and what’s the

23 problem about getting the €15,000 out, I can see that’s

24 a quicker point, but it doesn’t look as if it is quite

25 the point that I thought I was going to be dealing with

146 :1 first thing this morning which your Lordship asked me to
2 attend to, to sort things out.

3 I am in your Lordship’s hands. We can deal with

4 this, but there are issues about Withers, how much we

5 had been told was in the kitty, and various other

6 points. I am in your Lordship’s hands, really, as to

7 whether that is too much to transact this afternoon, or

8 whether we should try and get through that in some way.

9 There are some other housekeeping points which could

10 usefully be addressed as well, but I am in

11 your Lordship’s hands really.

12 MR JUSTICE HILDYARD: I have a rather dull, punishing

13 recollection that this issue of the life insurance was

14 raised some time ago.

15 MR LORD: A different policy, I believe, my Lord.

16 MR JUSTICE HILDYARD: Yes. It is a different policy, is it?

17 MR LORD: I’m checking, but I think this has happened —

18 this may be the second time. I will be corrected, but

19 I think before I was involved —

20 MR JUSTICE HILDYARD: Yes, I think it was when Mr Marshall

21 was involved.

22 MR LORD: I believe there may have been a hearing or a bit

23 of a hearing about whether there were issues with the

24 freezing injunction because of a move to encash a life

25 policy. I think, but I am going quite fast —

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Arkhangelsky [Master]

147 :1 MR JUSTICE HILDYARD: I raise it not so as we should all
2 battle to remember that which we cannot, and in your

3 case, you weren’t even there, but because that’s one of

4 the things I think ought to be checked.

5 At the moment, Mr Stroilov, let me tell you where

6 I am provisionally, so that you know why I provisionally

7 feel that this is not a matter which can be dealt with

8 right now.

9 MR STROILOV: Just to be clear I agree with that. My

10 instructions are not sufficient.

11 MR JUSTICE HILDYARD: My understanding from your e-mail this

12 morning was, in accordance with what you stated to me in

13 it, was that SG has been recently contacted by the legal

14 representatives of Bank of St Petersburg, that’s the

15 point of fact, and consequently — this is the result —

16 all the defendants’ accounts have now been blocked

17 completely, pursuant to the freezing order of 15 March,

18 and that that would have terrible consequences in terms

19 of the dishonouring of cheques.

20 That was my understanding. That concern of yours,

21 as so expressed to me, was premised on some contact by

22 the Bank — by Bank of St Petersburg with SG with this

23 result.

24 Now, what appears to emerge from the e-mail that we

25 have received is that in circumstances which are unclear

148 :1 at the moment, SG has focused on the problems of the
2 70,000 proceeds and whether they fall within the remit,

3 as Mr Lord says they do, of the freezing order. That

4 also seems to me a matter which needs to be explored,

5 particularly since it may be that some release from the

6 freezing order would be appropriate if these monies are

7 not to be used otherwise than for genuine living

8 expenses or legal expenses. That, too, is a matter

9 which needs to be carefully addressed, I think.

10 MR STROILOV: My Lord, I am afraid, and I do apologise for

11 that, I don’t think I am in a position to address this

12 issue now. Clearly I accept that what I have said in my

13 e-mail, that was to my best understanding of the

14 situation at that stage, and that does not quite match

15 what Madame Bidault says in her letter, having

16 investigated it from her own angle. I am afraid taking

17 instructions on the matter, which appears to be urgent,

18 in the middle of three almost impromptu

19 cross-examinations is not perfect.

20 So, I am afraid I am not in a position to say

21 anything. I haven’t got sufficient instructions, and

22 I am sorry for that cause.

23 My Lord, obviously it is three to five. I wanted to

24 say a few words on the timetable —

25 MR JUSTICE HILDYARD: Shall we round off on this.

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Bank St Petersburg v Vitaly Day 5

Arkhangelsky [Master]

149 :1 Mr Arkhangelsky, I do not know, and cannot know, the
2 communications between you and Mr Stroilov which led to

3 the e-mail which caused me such concern this morning,

4 but it does now appear from the record as it presently

5 stands that that e-mail was, regrettably, incorrect in

6 that it didn’t depict what the true concern was.

7 Now, that is unfortunate, and it also is bound to be

8 relied on in a sense with some concern as being

9 indicative of two dangers: one is that Mr Stroilov is

10 put in a particularly invidious position if he gets such

11 instructions and they prove incorrect, having regard to

12 all the worries that have been expressed that he is not

13 bound by ordinary professional rules.

14 The second is that the court is left with

15 an uncomfortable feeling that there might have been some

16 expectation that the court would — I won’t say this

17 horribly, but bounced into some precipitate action which

18 more measured approach, which was, in deference to him,

19 urged strongly by Mr Lord before he had had time to

20 really look at things. This causes me concern for at

21 least those two reasons. So I don’t want to deal with

22 this precipitately.

23 There is another reason why I don’t think we need,

24 which is that this problem has been, if I can put it

25 this way, hoving into view for the past month, as

150 :1 I understand it, and therefore there should be
2 a possibility of dealing with it more carefully.

3 Then the question is when.

4 MR ARKHANGELSKY: Your Lordship, I am sorry, can I explain?

5 I think there is some misunderstanding still. Can

6 I please explain the whole situation? Just give me two

7 minutes, please?

8 MR JUSTICE HILDYARD: I think that, amongst other things,

9 for the sake of good order, but also your and

10 Mr Stroilov’s protection, it would be best if this were

11 committed to writing, please, and then provided to my

12 clerk, as well as to Mr Stroilov, obviously, and to the

13 Bank, so that we can consider it more carefully and so

14 that you can express it after due deliberation and as

15 accurately as is possible.

16 I don’t think that I can sort of hear changing or

17 even elaborations on the hoof. This has caused me

18 sufficient concern that it must be crystallised. You

19 must then sign off on what you say is the position, and

20 we must proceed on that footing; all right?

21 Now, when do you wish to do the statement and when

22 do you wish the matter to be adjudicated?

23 MR ARKHANGELSKY: We shall make a statement, but what I want

24 to confirm from my point of view, in fact, the situation

25 is nearly the same as been told in the morning, and

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151 :1 I will put that in writing later today.
2 MR JUSTICE HILDYARD: I understand that there may be

3 a problem about meeting cheques if there is no money.

4 I can understand there is still urgency. What

5 I suggest, I think, subject to anything you or

6 Mr Stroilov say, is that I should adopt Mr Lord’s

7 suggestion of dealing with this through you tomorrow and

8 encourage you, since you have this at your fingertips,

9 to provide the statement over the course of the night so

10 that it is here by, say, 10.00, and we can deal with it

11 at, say, 11.00 am tomorrow, which will be 12.00 your

12 time.

13 MR ARKHANGELSKY: Okay.

14 MR JUSTICE HILDYARD: Is that all right?

15 MR ARKHANGELSKY: Yes, all right.

16 MR STROILOV: Just so Mr Arkhangelsky is clear, I want to

17 make it clear, what is suggested, Mr Arkhangelsky, is

18 that you deal with this by videolink. I won’t be able

19 to be here tomorrow. So hopefully that is all right.

20 I can’t help with this. Is that — I just don’t want

21 you to be under any misapprehension.

22 May I just confirm that?

23 MR ARKHANGELSKY: Yes.

24 MR STROILOV: (Speaks Russian).

25 Yes, it is all right. I do apologise, my Lord, it

152 :1 is slightly chaotic, but that’s all right.
2 MR JUSTICE HILDYARD: If someone on your side, Mr Lord,

3 could try and look up the previous occasion in

4 the transcripts when the whatever, the policy —

5 MR LORD: I have the judgment, my Lord, sorry, it’s at

6 {K1/8/1}. I do apologise, I should have had that

7 earlier.

8 MR JUSTICE HILDYARD: Did I give a judgment?

9 MR LORD: You did.

10 MR JUSTICE HILDYARD: It shows how poor one’s memory is.

11 MR LORD: Your Lordship gave a judgment, seemingly it is

12 dealt with inter alia this life insurance policy issue

13 and the freezing injunction, I need to check whether it

14 has been varied at all, but the original freezing

15 injunction is at {J1/1/1}, that’s Mr Justice Sales —

16 MR JUSTICE HILDYARD: What did I say in happier days?

17 MR LORD: I’m not sure, my Lord.

18 MR JUSTICE HILDYARD: Okay, well I will read it.

19 MR ARKHANGELSKY: Your Lordship, if you allow, I just

20 want — if you still allow while Mr Stroilov is there,

21 I need just two minutes to explain the situation, just

22 to avoid any misleading by Mr Lord.

23 MR JUSTICE HILDYARD: What is your point?

24 MR ARKHANGELSKY: Can you give me this chance?

25 MR JUSTICE HILDYARD: Well, I will for literally two

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153 :1 minutes, because I want you to have the chance to
2 elaborate and carefully deliberate your true complaint.

3 MR ARKHANGELSKY: I need just two minutes, very briefly.

4 MR JUSTICE HILDYARD: Two minutes, on you go.

5 MR ARKHANGELSKY: Okay. Just for your understanding that

6 life insurance policy in France is a kind of deposit

7 with tax incentives scheme, and we’ve always been living

8 like this, so it’s in the name of our family, and we

9 were transferring money from this life insurance policy

10 to our current account and spending this money on our

11 living expenses, based on the freezing order.

12 The process is that we had to withdraw money from

13 this life insurance policy. We have had to give

14 a written application to the bank to transfer money from

15 life insurance policy to our current account, daily

16 account with the same bank. It normally takes in

17 between two and four weeks, because it’s the bank who

18 invest, and they need money to be released from their

19 stocks.

20 So we made this application in the standard, regular

21 way in the beginning of January, and we are waiting for

22 this money the whole month, and suddenly we decided to

23 go to the bank today and check where our money is

24 because we don’t have money to live so the accounts are

25 empty, and normally we would expect that everything is

154 :1 done.
2 But due to the change in some management in

3 the local office, and what I’ve been — what my wife has

4 been told orally by the vice director of the office,

5 that they got some letter from the Bank of St Petersburg

6 recently, again enclosing this freezing order, that’s

7 why they are not able to release these funds and we

8 cannot do anything unless the new court order is. So

9 that’s it.

10 So we do have our accounts empty, we don’t have any

11 money to live and to survive. So that’s the fact.

12 MR JUSTICE HILDYARD: Well, thank you. That was admirably

13 brief.

14 You may wish to revise — you will have the

15 transcript, it will assist you putting that into

16 a statement. I dare say you will have the chance to

17 discuss that without me or anyone else being there, with

18 Mr Stroilov. If there are points in it you wish to

19 elaborate or refine, well and good. Try and have this

20 to me — in fact, have it to me by 10.00 am tomorrow.

21 In the meantime, Mr Lord will be taking or

22 double-checking his instructions as to whether there has

23 recently been any communication by the

24 Bank of St Petersburg with SG, such as was intimated by

25 your wife, she had been told by the vice director of

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155 :1 your bank, or any other communication which might lie at
2 the root of some change in the apparent policy of

3 the bank.

4 MR LORD: And if there is a letter, if there is something

5 within the bank, they have a copy of the letter, then

6 a copy of that should be produced as well so we can tie

7 down the alleged communication —

8 MR JUSTICE HILDYARD: It would assist if your bank, if it

9 does have a letter which has prompted this response,

10 then of course the easiest thing would be for them to

11 provide it to you and you to provide it to all of us.

12 MR STROILOV: I am concerned that —

13 MR ARKHANGELSKY: I’m sorry, my Lord, we asked about that

14 and they said that it’s the internal issue of the bank.

15 It’s not the issue to be handled by the local office

16 where we are served in, and they would not provide us

17 any information until only new court order to be served

18 to the bank in the official way.

19 So that is it. We are not in a position to get

20 anything, and that’s why I asked my French advocate,

21 Ms Bidault, to contact the bank directly and to write

22 you from the first mouth what is the real situation. So

23 the information is limited to what she was able to get.

24 MR JUSTICE HILDYARD: Well, it is important that your

25 statement should address this point, it having been

156 :1 expressly raised.
2 Good. Well, we shall deal with that. You will

3 provide the witness statement in conjunction, if

4 Mr Stroilov is able to assist, dealing with these

5 points, by 10.00 am.

6 Mr Lord will, in the meantime, reconfirm his

7 instructions with respect to any correspondence between

8 Bank of St Petersburg and SG which might have prompted

9 this. A file will be provided for me with respect —

10 well, any references in the existing files will be

11 alerted to me so I can read them carefully, and I think

12 I will need to know — and this will also have to be

13 part of the statement — what, either in the past or

14 proposed for the future, use of these monies is

15 proposed.

16 MR LORD: And, my Lord, I should flag up that we will give

17 your Lordship the references, this does raise some asset

18 issues here, some important issues, particularly in

19 the light of submissions about who can and can’t come

20 for a day or two in court.

21 MR JUSTICE HILDYARD: I don’t know how far it stretches, but

22 there will be issues as to whether this policy was

23 properly disclosed and if any part of it has been used,

24 whether the purposes were within or without the terms of

25 the freezing injunction. Of course, even if they were,

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157 :1 that does not necessarily mean that the matter cannot be
2 reviewed, but it does mean that the court must know very

3 precisely what has been going on and what is proposed in

4 the future.

5 Are you content, Mr Stroilov, Mr Lord, with that?

6 MR LORD: Yes, my Lord.

7 MR STROILOV: Yes, my Lord, I think that sounds sensible,

8 and I do apologise for the chaotic way in which it was

9 presented, but it seems to be an urgent matter.

10 MR JUSTICE HILDYARD: Mr Stroilov, I suspect you were

11 preparing cross-examination — I didn’t mean to cut

12 across you — this morning, and that this matter is one

13 of those things which needs to be very carefully and

14 deliberately set out, Mr Lord was right, lest one jumps

15 to conclusions which are not warranted.

16 MR STROILOV: My Lord, I think we have a dispute on

17 timetable. Can we address you on paper on that, or

18 perhaps I can send a letter.

19 MR LORD: No, no, my Lord, the timetable, really, should be

20 completely unobjectionable. I do — I have been as

21 flexible as — I have been pretty flexible this week, in

22 my submission, about timetabling and translations and so

23 on, and we have been very accommodating, and I am

24 surprised to hear an objection when what we are doing

25 appears to accommodate Mr Stroilov.

158 :1 Does your Lordship have the revised trial timetable?
2 MR JUSTICE HILDYARD: Yes.

3 MR LORD: Your Lordship will see, and we looked at this,

4 I think, yesterday, or maybe — yes, yesterday — when

5 we were given to understand that the first week, this

6 week, was looking a bit full, and we should consider

7 lightening the load this week, and we considered various

8 time estimates for other witnesses and Mr Stroilov

9 indicated yesterday that he would be up to four days

10 with Mr Savelyev and three days with Miss Mironova and

11 two days with Ms Volodina. We were left to consider

12 what could be done about the timetable.

13 My intention is to call Mr Guz on the second week.

14 MR JUSTICE HILDYARD: Sorry, say that again.

15 MR LORD: Mr Guz, who is the current chairman of the Bank.

16 MR JUSTICE HILDYARD: Someone slammed the door and I didn’t

17 hear what you said.

18 MR LORD: Mr Guz is the chairman of the Bank. Your Lordship

19 saw him in court yesterday, he has come over,

20 conscientiously, he has flown back for a very big

21 meeting —

22 MR JUSTICE HILDYARD: Yes, get to the point, when are you

23 proposing to —

24 MR LORD: And he was due to give evidence this Thursday.

25 MR JUSTICE HILDYARD: When is he proposed now?

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159 :1 MR LORD: Monday next week, at 10.30, Mr Guz will go into
2 the witness box.

3 MR JUSTICE HILDYARD: February 8.

4 MR LORD: February 8. And Mr Stroilov indicated that he

5 would be up to two days with Mr Guz. Up to two days. so

6 Mr Guz will be finished, in my respectful submission,

7 even on Mr Stroilov’s estimate, by the end of Tuesday.

8 Then I propose to call Ms Volodina, who is down to

9 come next Tuesday as well on the 9th, if time permitted.

10 So she has been plugged in for some time and I propose

11 to call her either on the Tuesday, or if in fact it

12 becomes clear that Tuesday will be taken for Mr Guz, she

13 can come on Wednesday, and we can start, if need be, at

14 Wednesday lunchtime or we could even start her on

15 Thursday, and the estimate for her was two days as well.

16 So it was up to two days, so we have up to four

17 days’ worth of witnesses. They are two separate

18 witnesses, they have always been down for the first two

19 weeks, and there can be no objection. Within the

20 parameters of fairness of notice, I am fully entitled to

21 call the witnesses that I choose to call and I so

22 choose. I was invited by Mr Stroilov and your Lordship

23 to consider standing Mr Savelyev out beyond Paris.

24 I registered my desire to call some more senior

25 witnesses and I am going to do that. Mr Guz is the

160 :1 witness that I am going to call.
2 Then I suggest that we leave — I am in

3 your Lordship’s hands as to whether we plug in Monday,

4 Tuesday, Wednesday, Thursday with Friday off, or Monday,

5 Tuesday and then Wednesday off for Mr Stroilov, coming

6 back on Thursday and Friday for Ms Volodina.

7 MR JUSTICE HILDYARD: Who are we having on 11th and 12th?

8 MR LORD: Sorry, my Lord?

9 MR ARKHANGELSKY: Sorry, your Lordship, they are closing.

10 Here, may I just ask you to allow to leave, because they

11 are closing here?

12 MR JUSTICE HILDYARD: Yes, I’m so sorry, I don’t want you to

13 be trapped there.

14 MR ARKHANGELSKY: They are closing here, it is not my fault.

15 Thank you, see you tomorrow.

16 MR JUSTICE HILDYARD: Yes, bye bye.

17 MR ARKHANGELSKY: Bye.

18 MR LORD: Really, it would be Mr Guz and Ms Volodina, so

19 there will be two witnesses next week.

20 MR JUSTICE HILDYARD: Yes.

21 MR LORD: In my respectful submission, it may not be four

22 days’ worth of business, but we are conscious of the way

23 this needs to go before Paris, and therefore we are

24 building in, conscious of your Lordship’s position —

25 I don’t mean that disrespectfully, but the need to make

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161 :1 sure that there is plenty of time, so Mr Stroilov has
2 plenty of time, even in his most ambitious aspirations

3 for trial timetabling, that gives him tomorrow and

4 Friday with no more witnesses, so he has Thursday,

5 Friday, Saturday, Sunday.

6 MR JUSTICE HILDYARD: Sorry, I am being slow. All that is

7 proposed really is that for next week we should focus

8 only on Mr Guz and Ms Volodina.

9 MR LORD: Ms Volodina, who is also a fairly senior Bank

10 employee.

11 MR JUSTICE HILDYARD: The one we will not then have done

12 from the list for this week is Ms Yashkina. She is to

13 come in later, is she?

14 MR LORD: She is, my Lord, although I need to consider —

15 I will take stock after Paris. I will consider when she

16 can come. I may or may not make applications for video

17 link. I reserve all my position for a witness who is

18 being stood further down. It will depend a bit on how

19 the other evidence goes as to how important Ms Yashkina

20 seems then to be, and I will give a fair notice of any

21 change in that regard, but I don’t commit to call every

22 witness if, after three or four witnesses in Paris, it

23 looks like things are going a different route.

24 MR JUSTICE HILDYARD: What about the 15th, Monday, the day

25 before we go to Paris?

162 :1 MR LORD: My Lord, we would suggest keeping Ms Stalevskaya
2 there to try and get her out of the way in that slot.

3 So we would have some witnesses to put in afterwards,

4 but so be it. We will have to find some time, we will

5 have to look at the schedule, look at the experts and we

6 will have to think what can be done.

7 MR JUSTICE HILDYARD: All right, now, Mr Stroilov, you

8 object to that?

9 MR STROILOV: I think, well, essentially, I say one of

10 the — I just can’t go on at this pace, frankly, it is

11 physically impossible.

12 MR JUSTICE HILDYARD: I have every sympathy. It is

13 an exhausting business. I indicated that earlier and

14 I indicate it again.

15 But you do have — I am happy to say for you —

16 tomorrow, Friday, Saturday and Sunday. This has been

17 a less witness-heavy week than had been envisaged, and

18 next week is going to be a very considerably less heavy

19 week than had been envisaged, because Mr Savelyev is

20 a very important witness, in all likelihood.

21 MR STROILOV: Yes.

22 MR JUSTICE HILDYARD: It seems to me, unless you say

23 otherwise, having expressed my admiration and

24 understanding, that what Mr Lord is offering is rather

25 reasonable, isn’t it?

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163 :1 MR STROILOV: Well, my Lord, I would say that, really —
2 I am not going to complain. I think my first point is,

3 we shouldn’t pretend that really it was a timetable

4 which was fixed and I have jeopardised it.

5 MR JUSTICE HILDYARD: But he is not. We are abandoning it

6 almost wholesale for the first two weeks. I mean, we

7 can’t fight old battles. The battle has moved to

8 a different pitch.

9 Now, as far as I can see, I will be entirely

10 flexible with you if Mr Lord agrees and his witnesses

11 are available, as to whether you should have a break

12 between Mr Guz and Ms Volodina, or whether we should

13 have a break on the Friday. He has indicated to me he

14 is happy. We will accommodate you and, thereby,

15 hopefully allow you, on your present estimate, a day, or

16 at least a half day, to gather your thoughts with

17 respect to the subsequent witness. That doesn’t seem

18 unfair, really, does it?

19 MR STROILOV: I’m more concerned about Mrs Stalevskaya being

20 put on the last day.

21 MR JUSTICE HILDYARD: How long did you reckon for her?

22 MR STROILOV: Well, I do think that one day must be enough

23 but —

24 MR JUSTICE HILDYARD: I’m sorry to be harsh, but you have

25 Saturday and Sunday for that.

164 :1 MR STROILOV: Well, after the whole week of really doing
2 that and —

3 MR JUSTICE HILDYARD: It is very harsh, but —

4 MR STROILOV: I don’t press the point.

5 MR JUSTICE HILDYARD: It is hard, Mr Stroilov, and I have

6 great human sympathy for you, but we have to move the

7 case on. It is important for your clients, but it is

8 also important for other people that a proportionate

9 time should be spent, and this case is being afforded

10 flexibility which, in the new rules, is not ordinarily

11 afforded. It’s just one of those things; that the

12 pressure of business is such that people have to move

13 on. It’s not like the US Supreme Court when you watch

14 the sands tip out and at the end of half an hour if you

15 have just said, «and my most important point is …» and

16 the sands run out, that’s tough, it isn’t like that, but

17 it isn’t endlessly flexible.

18 MR STROILOV: Indeed not. I accept this. I reluctantly, and

19 I do hope I won’t have to resort to that, I reserve the

20 right to leave one of these witnesses to

21 Mr Arkhangelsky, but I hope to avoid that, and we will

22 see.

23 MR JUSTICE HILDYARD: Everything I say is said in

24 the context of my understanding how difficult it is and

25 my admiration for what you do. Nothing detracts from

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165 :1 that.
2 We will abide by that suggestion, which seems to me

3 to balance the entitlement of a party, subject to

4 overriding considerations of fairness, to call his

5 witnesses in the order he proposes, and for the fair

6 expectation that people should not be endlessly on

7 standby and then stood down.

8 MR STROILOV: Thank you.

9 MR JUSTICE HILDYARD: Mr Lord, is that …

10 MR LORD: That’s very fair, my Lord.

11 Just for your Lordship’s note, I handed up some

12 photographs which have been uploaded.

13 MR JUSTICE HILDYARD: Yes, these ones.

14 MR LORD: Those are from Google Maps, I think, Google Earth.

15 MR JUSTICE HILDYARD: And they are on different dates.

16 MR LORD: They are, and they have their Magnum references.

17 They are from the Western Terminal, they follow year on

18 year, more or less, and there is a zoom and there is

19 a more remote picture, and your Lordship will —

20 MR JUSTICE HILDYARD: So you may see a development of

21 the site.

22 MR LORD: If your Lordship were to look at the railway

23 development and tracks and foundations, your Lordship

24 will see when those look as if they were first

25 constructed.

166 :1 MR JUSTICE HILDYARD: And Mr Stroilov has a copy of this?
2 MR STROILOV: It’s the first time I hear of this.

3 MR LORD: We have been uploading since — we have been doing

4 this since we heard the questioning on —

5 MR JUSTICE HILDYARD: No one is going to make any points on

6 this but it is not wrong for me to have a look in the

7 meantime.

8 MR LORD: No, and they are uploaded and we have copies for

9 Mr Stroilov.

10 MR JUSTICE HILDYARD: I have one or two other things, I am

11 very sorry to the court officials for delaying them yet

12 further, and to all of you.

13 A mention was made of the Russian feed issue; has

14 that been sorted?

15 MR LORD: Your Lordship will be grateful for a rest from my

16 voice.

17 MR JUSTICE HILDYARD: Yes, Mr Birt.

18 MR BIRT: No warranty for my technical aptitude in

19 describing the complexity of it, but I will do my best.

20 The room is set up in Nice, it is a conference room

21 and it has the live video feed and I think your Lordship

22 wanted a view on the logistics involved and the cost

23 involved. The cost, I am told, of the room hire

24 including the videolink for each day is €3,623 per day.

25 That is based on a six-and a half hour day that it is

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167 :1 usually booked for, a bit before and a bit after court.

2 MR JUSTICE HILDYARD: Yes, and that does not include a feed
3 of the Russian?

4 MR BIRT: What that includes is one audio feed, because

5 there’s only one audio channel down the line, and what

6 they have the choice of in Nice is selecting — rather

7 like we have the choice of selecting — they can either

8 select to have no headphones on and just have the feed

9 from the ambient court volume, so whoever is speaking

10 and whatever language they are speaking they can hear,

11 or they can choose channel 1 that your Lordship and

12 ourselves have been listening to in English, and they

13 can have everything in English, the questioner in

14 English and the witness through the interpreter in

15 English or they can choose channel 2 which has the

16 mirror effect, in other words, they hear Russian when we

17 are talking in English and they hear Russian from the

18 witness.

19 So they can select, rather like we can in court, any

20 of those three. The difference is that everybody

21 sitting in the room in Nice has to sign up to one of

22 those three options, because there is only one audio

23 feed, so they can only have one, and they just have to

24 communicate to the gentleman in court which of those

25 three options they like.

168 :1 MR JUSTICE HILDYARD: So in real terms it calls for Mr and
2 Mrs Arkhangelsky to agree whether to listen in English

3 or in Russian?

4 MR BIRT: Or the hybrid of whoever is speaking.

5 There is a work around, because it has taken quite

6 a lot of time to work out what it might be, to fix up

7 a second audio line going down to Nice.

8 Now, there isn’t a second hardwired telephone line

9 in court, as I understand it, or at the other end, so it

10 requires a mobile phone link. A mobile phone can be

11 made available and what happens is that goes into the

12 interpreters’ box, effectively, to take the Russian feed

13 over a mobile phone, and Mrs Arkhangelskaya can sit in

14 the room on a mobile phone listening to it.

15 That will require the cost of a mobile phone call

16 from London to Nice for the duration of the court day.

17 I don’t know if we have an exact figure, but it is about

18 £130 or £140 or something like that. We are unwilling

19 to incur that unless it is required, but it is fair to

20 say that in the scheme of the cost that’s already been

21 incurred of €3,600 a day, it is relatively marginal.

22 MR JUSTICE HILDYARD: I will think about that. I’m slightly

23 worried about whether there are any court rules about

24 this as well, because normally everything has to be on

25 a feed which is monitored.

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169 :1 MR BIRT: And secure. I should say that the mobile phone
2 option for the second audio feed is, in a sense,

3 untested. This case is going into new territory in all

4 sorts of respects and this will be one too. What I’ve

5 been told is nobody can give any warranty about the

6 quality of that feed or the interference — anybody’s

7 mobile phone could be interfered with by all sorts of

8 things and it would be subject to those pressures if put

9 on. So, in a sense, that is the option that’s available

10 if they want it. I’m told we are willing to fund it but

11 not constantly, only if and as required.

12 MR JUSTICE HILDYARD: Mr Stroilov, Mr Arkhangelsky had to

13 flee, lest he be imprisoned, but he will be able to read

14 this on the transcript, and you have heard it: without

15 making any decision, my provisional estimate is that the

16 arrangement so far achieves the object which is to

17 enable Mr and Mrs Arkhangelsky to know what is going on,

18 and all it requires is, really, a bit of cooperation

19 between them should they both attend, which has not

20 happened yet, and I must say had been intimated to me

21 would be unlikely to happen ever because of childcare

22 responsibilities, for them to understand what is going

23 on.

24 I am nervous about the additional mobile feed, and

25 unless that were insisted on so that I had to make

170 :1 a decision on it, my instinct is rather against it.
2 I think the efforts made are very great, and part of me

3 thinks: well, an English jurisdiction was selected and

4 quite a lot would be happening in English in any event,

5 even if they were here.

6 MR BIRT: My Lord, I should have added one other thing, but

7 I think your Lordship picked it up yourself when this

8 was last raised, which is Mr Arkhangelsky has his real

9 time feed in Nice already as well, so should the

10 occasion arise that they want to listen in Russian, but

11 watch in English, that is a —

12 MR JUSTICE HILDYARD: But monitor in English —

13 MR BIRT: — and I think that is also costing £100 or so per

14 day, but that is being run in any event.

15 MR JUSTICE HILDYARD: I think collaboration, a recognition

16 of the difficulties and reasonableness might indicate

17 that the position as it presently is is pretty good, but

18 I will let you discuss that.

19 MR STROILOV: I’m not sure, I’m rather confused.

20 I understand that the claimants were asking for

21 something, which I don’t quite understand. My

22 understanding is that definitely it’s not a question of

23 Mr and Mrs Arkhangelsky agreeing between themselves.

24 The Russian feed — we were told that the Russian feed

25 is unavailable on demand but it can be made available

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171 :1 with reasonable notice.
2 MR JUSTICE HILDYARD: My understanding is that channel 2,

3 which I have to say I have not been an avid listener of,

4 is available in Nice?

5 MR BIRT: I think all they need to do is give prior notice.

6 I think what they can’t do is change their mind every

7 five minutes.

8 MR JUSTICE HILDYARD: They can’t have both. They have to

9 settle on something for the session.

10 MR BIRT: For the day or for the session, my Lord.

11 MR JUSTICE HILDYARD: Perhaps you could let them know, and

12 if there are days on which Mrs Arkhangelskaya really

13 wants to be there —

14 MR STROILOV: That is something I have promised to RPC to

15 do, give them notice.

16 MR JUSTICE HILDYARD: Thank you.

17 MR STROILOV: But I reserve the right for Mr Arkhangelsky to

18 address you on that, because I don’t really know what

19 the concerns are but he will lead this and address you

20 tomorrow.

21 MR JUSTICE HILDYARD: I will leave that to further

22 discussion between you.

23 Then Mr Arkhangelsky was a bit worried about

24 the cameras. I don’t know whether — I think he wanted

25 to see everybody and the witness, and at the moment

172 :1 I think he can see you, occasionally if I am looking
2 sleepy, it hones in on me, probably, but it doesn’t show

3 the witness, as I understand it?

4 MR BIRT: As the new technology representative —

5 MR JUSTICE HILDYARD: Yes, you are the guru on this.

6 MR BIRT: — I’m not sure it is a good idea, really.

7 I think where we have got to is we have been talking to

8 the Rolls Building staff quite a lot and at the moment

9 they tell us the camera isn’t movable but it may be that

10 there are still avenues — I look behind me and I don’t

11 know if there are further avenues. We have made efforts

12 to try and see if it could be moved somewhere else. If

13 it can’t be moved, the only other option would be to

14 move the witness, my Lord.

15 MR JUSTICE HILDYARD: If Mr Arkhangelsky is cross-examining,

16 the matter will come into high relief, which is why

17 I raise it now. You had better work out some witness

18 positioning so that he has a — I think what fairness

19 would require is he can really see the witness at least

20 as clearly as if that witness was being cross-examined

21 on videolink personally.

22 MR BIRT: The other option which I know has been thought of

23 is whether the interpreters’ box can be moved, because

24 there is another camera at that end of the court which,

25 my Lord, I don’t think you can. You can see the

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Arkhangelsky [Master]

173 :1 reaction from the interpreters’ box at that suggestion,
2 my Lord. I think they also need a clear sight line to

3 the witnesses.

4 MR JUSTICE HILDYARD: I am sure.

5 MR BIRT: We are beset with problems but we will give it

6 some further thought, my Lord.

7 MR JUSTICE HILDYARD: Otherwise we will simply have to be

8 flexible as to where the witness sits in that result.

9 MR BIRT: We will give it further thought and see if there

10 are other people who can be roped in to assist with that

11 tomorrow.

12 MR JUSTICE HILDYARD: Thank you.

13 MR BIRT: My Lord, there is one other issue which may fall

14 within my new bailiwick, which is your Lordship’s query

15 from the other day. I think you received a request from

16 somebody. I think we have tracked this down. I think

17 what it is is that the people operating the Magnum

18 system, Opus 2, what they can provide within Magnum is

19 the audio feed from court, so that when you look at

20 a daily transcript through the Magnum system, you can

21 also click on any particular part of it.

22 MR JUSTICE HILDYARD: And hear it.

23 MR BIRT: And hear it back. But my understanding is they

24 need the permission of the parties and your Lordship to

25 do that, and I think it was that request which found its

174 :1 way to you. Certainly for our part, we are more than
2 happy, I think it is a useful tool available to us,

3 available to Mr Arkhangelsky as well. There might be

4 a slight concern — I think this was one of the points

5 just raised, that that shouldn’t be disseminated further

6 or more widely, but certainly for the parties to

7 the proceedings to be able to hear it back may prove

8 useful.

9 MR JUSTICE HILDYARD: I am content with that, but it must

10 not be disseminated and it must not itself be recorded.

11 It must be available only on the Magnum system, if you

12 see what I mean, and not parcelled up for dissemination

13 elsewhere, by whatever means, whether on a disk or

14 anything else. There must be no attempt to duplicate

15 that feed.

16 MR BIRT: My Lord, certainly that would be completely fine

17 with us.

18 MR JUSTICE HILDYARD: Yes.

19 MR BIRT: And presumably Mr Stroilov and Mr Arkhangelsky

20 agree to that.

21 MR JUSTICE HILDYARD: If you would like that, then it must

22 be on those terms.

23 MR STROILOV: Quite, I think, really what our concern is, we

24 would like, say, Mrs Arkhangelskaya to be able to follow

25 this so that would be helpful to us.

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Arkhangelsky [Master]

175 :1 MR JUSTICE HILDYARD: Very good.
2 MR STROILOV: Of course we don’t propose to —

3 MR JUSTICE HILDYARD: It just must be available to

4 the parties and their advisers, but I don’t want

5 uncontrolled copies.

6 MR STROILOV: Yes.

7 MR JUSTICE HILDYARD: That’s very helpful, thank you.

8 I was asked about times for the Paris hearing, and

9 I imagine that you are discussing that between

10 yourselves.

11 MR LORD: My Lord, could I suggest, for my part, could we

12 start at 10.30 am on the first day, on the Wednesday,

13 and see how we go?

14 MR JUSTICE HILDYARD: Yes.

15 MR LORD: Potentially having either 10.00 until 4.00, or

16 10.30 until 4.15/4.30, maybe slicing up the day slightly

17 differently, but roughly 10.30 am until 4.30, and on the

18 first day a 10.30 am start to allow set up and

19 orientation.

20 MR JUSTICE HILDYARD: And despite the value of tradition,

21 I should imagine that in Paris we will be in suits?

22 I think that that would be better, lest we have trouble

23 on the tube.

24 MR LORD: Or not.

25 MR JUSTICE HILDYARD: Okay, that sounds right, but if

176 :1 Mr Stroilov, on reflection, wishes to say other, you
2 must say so.

3 I have asked about photographs of witnesses. It may

4 be that some additional hard copies will be necessary of

5 documents which appear to be revisited occasionally,

6 which are not — I think we will identify repeats as we

7 go along, and I would like an additional core bundle, if

8 I can put it, of documents which have emerged as

9 important to the case.

10 MR LORD: Yes.

11 MR JUSTICE HILDYARD: I have an abiding worry about the

12 expert witnesses, but I think I shall keep them to

13 myself for the moment.

14 MR LORD: Yes, and there is a point on Mr Steadman, my Lord,

15 which we will raise tomorrow. There has been a letter

16 from Mr Steadman.

17 MR JUSTICE HILDYARD: Yes.

18 MR LORD: As I made plain earlier in the week, I had in mind

19 possibly trying to intercept any — or at least to

20 preserve the possibility that he might come, rather than

21 have him stood down now, so it might be useful to raise

22 that with —

23 MR JUSTICE HILDYARD: I imagined that you might be thinking

24 of alternatives, and I have done a little bit of

25 research on that and we will see how it goes.

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Arkhangelsky [Master]

177 :1 Is that it?
2 MR LORD: Yes, my Lord. I think that is it.

3 MR JUSTICE HILDYARD: So we are reconvening at 11.00 am

4 tomorrow.

5 MR LORD: Yes, my Lord. There are various outstanding

6 points. Various pleadings points were going to be

7 tidied up, the protocol lies with the defendants to

8 agree the request for Mr Nazarov’s notes and FTI

9 unredacted and so on. None of that has actually

10 happened. We will raise it tomorrow because, whilst we

11 are performing our side of the housekeeping, it is right

12 to note —

13 MR JUSTICE HILDYARD: Perhaps they could be listed as

14 an aide-memoire, and now that Mr Stroilov at least

15 doesn’t have the horrendous pressure of the morrow,

16 maybe some progress can be made, but this has been, no

17 doubt, a pretty wearing week.

18 MR STROILOV: I will see what I can do, but I would like,

19 really, advance notice of any issue that is going to be

20 raised tomorrow.

21 MR JUSTICE HILDYARD: You have been given the notice but you

22 are to be provided with an aide-memoire. You have been

23 told about these things but in the gallop of the case,

24 maybe they have slipped into the background and,

25 therefore, an aide-memoire will be useful.

178 :1 MR LORD: My Lord, we will produce that overnight, just
2 a list of points. We will e-mail it to Mr Stroilov and

3 Mr Arkhangelsky and your Lordship, if that is all right,

4 and we will seek to raise that with Mr Arkhangelsky

5 tomorrow.

6 MR JUSTICE HILDYARD: By 10.00 am I want this statement, and

7 at 11.00 — though not in your presence, Mr Stroilov —

8 we will reconvene. I wish you some rest, and then some

9 time for prep, and well done so far in enduring it. It

10 is always an endurance test.

11 MR STROILOV: I am much obliged.

12 MR JUSTICE HILDYARD: Thank you.

13 (5.37 pm)

14 (The court adjourned until 11.00 am on
15 Thursday, 4 February 2016)

15

16

17

18

19

20

21

22

23

24

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Arkhangelsky [Master]

179 :1 INDEX
2 PAGE
3 Housekeeping ………………………………….. 1
4 MS ELENA SERGEYEVNA BLINOVA …………………….. 6
5 (Continued)
6 Cross-examination by MR STROILOV ………….. 6
7 (Continued)
8 Re-examination by MR LORD ……………….. 45
9 Questions by MR JUSTICE HILDYARD …………. 57
10 Further cross-examination by MR STROILOV …. 68
11 Housekeeping …………………………………. 72
12 MS NATALYA YURIEVNA PATRAKOVA ………………….. 79
13 (Affirmed)
14 Examination-in-chief by MR LORD ………….. 80
15 Cross-examination by MR STROILOV …………. 81
16 Questions by MR JUSTICE HILDYARD …………. 93
17 Further cross-examination by MR STROILOV …. 95
18 Questions by MR JUSTICE HILDYARD ………… 96
19 Housekeeping …………………………………. 97
20 MRS EKATERINA VYACHESLAVOVNA ………………….. 102
21 SHABALINA (Affirmed)
22 Examination-in-chief by MR LORD …………. 102
23 Cross-examination by MR STROILOV ………… 103
24 Questions by MR JUSTICE HILDYARD ………… 136
25 Housekeeping ………………………………… 144

0

180 :1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

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additional ( 10 ) 16:8
Again, ( 44 ) 7:23 12:11
148:4 149:7 150:9
apart ( 6 ) 14:4 30:25
Arkhangelsky ( 121 )
A 17:11 20:18 40:21
14:19 18:19 21:18
156:12 161:9 164:8
83:19 83:25 95:3
3:19 4:2 4:17 14:9

114:22 116:8 141:1
22:9 22:12 22:17
170:13 173:2 173:21
129:7
14:24 23:17 27:21

169:24 176:4 176:7
22:22 28:3 28:4
alternatively,133:10
apartment ( 2 ) 80:8
28:24 31:14 34:18

A13,88:5

address. ( 24 ) 34:16
28:14 31:20 33:18
alternatives,176:24
102:11
35:4 35:5 35:12 35:16

A1488:3
34:20 37:3 37:6 37:7
42:8 42:21 44:10
Although ( 2 ) 138:2
apologies, ( 7 ) 15:21
35:17 35:23 36:2 36:5

A15. ( 2 ) 88:4 88:5
37:9 55:8 61:15 61:20
56:22 70:21 73:2
161:14
19:21 30:24 44:22
37:13 40:18 49:22

A23.»88:12
61:22 62:7 62:10
73:16 81:24 82:7
always. ( 14 ) 10:1 30:1
45:12 99:23 134:25
51:17 51:22 52:7

abandon128:8
62:12 62:13 77:5 80:6
83:17 83:25 85:6 85:9
31:2 33:22 60:12 63:8
apologise ( 14 ) 11:15
52:13 52:25 53:2

abandoning163:5
102:9 110:18 112:11
100:18 100:20 106:21
71:16 107:5 122:6
38:14 88:18 93:9
53:14 54:1 54:18

abide165:2
148:11 155:25 157:17
115:9 115:11 116:18
126:22 138:17 153:7
113:9 113:22 128:13
54:24 55:18 56:8

abiding176:11
171:18 171:19
116:19 116:19 118:22
159:18 178:10
130:11 137:6 140:6
56:17 57:10 57:15

above59:4
addressed ( 7 ) 57:10
126:4 127:17 128:13
ambient167:9
148:10 151:25 152:6
61:15 63:15 65:18

absence108:23
78:6 99:10 101:2
129:4 135:1 154:6
ambitious161:2
157:8
65:20 66:25 77:11

absolutely ( 12 ) 14:20
112:18 146:10 148:9
158:14 162:14
amended64:2
apparent155:2
78:23 81:22 84:13

28:15 51:12 66:4
addresses, ( 4 ) 30:21
against ( 20 ) 7:9 7:21
amendments ( 2 ) 63:20
apparently56:20
85:17 87:3 88:4 88:6

67:24 94:18 108:22
34:19 37:11 61:25
7:22 8:1 8:1 9:1 9:2
118:18
appear ( 8 ) 29:14 36:14
88:19 88:22 89:3

114:7 118:11 120:23
Addressing143:18
9:7 9:12 10:4 11:2
amicable35:24
46:14 56:15 108:5
89:17 92:21 93:10

136:9 139:1
adequate108:6
51:6 55:19 63:17
among89:13
133:11 149:4 176:5
99:5 99:14 99:16

accelerate23:19
adjourned178:14
114:2 116:3 120:6
amongst ( 3 ) 42:4
appears ( 10 ) 28:17
99:24 100:16 100:22

accelerated24:3
adjournment, ( 4 ) 121:22 145:13 170:1
107:13 150:8
34:8 57:9 112:6
101:7 105:9 105:15

accept ( 12 ) 1:25 4:9
72:13 75:21 78:2
ago ( 2 ) 126:18 146:14
amount, ( 8 ) 39:20
132:23 142:4 145:12
105:24 106:5 106:6

11:20 11:22 11:25
79:17
agree ( 12 ) 9:3 11:23
58:16 58:17 59:14
147:24 148:17 157:25
106:11 106:19 107:5

24:10 38:7 44:16
adjudicate,4:20
11:25 100:22 101:7
82:20 124:10 124:11
appendix, ( 2 ) 142:3
107:21 108:12 111:17

119:12 131:23 148:12
adjudicated?150:22
121:6 121:7 123:4
124:12
142:7
119:9 120:6 121:23

164:18
adjustments48:4
147:9 168:2 174:20
amounts ( 3 ) 17:6
applicable137:8
122:2 123:11 124:18

accepted ( 6 ) 10:7
administration ( 3 ) 177:8
18:22 39:22
application ( 19 ) 2:14
126:11 127:11 127:14

10:13 51:5 54:13
28:11 29:18 63:11
agreed ( 4 ) 1:15 14:13
analyses123:20
12:11 103:25 122:20
127:19 129:1 129:13

114:17 118:15
admirably154:12
19:9 101:5
analysis115:19
123:6 123:12 123:14
130:16 133:17 136:1

accepting74:13
admiration ( 2 ) 162:23
agreeing170:23
angle.148:16
124:1 124:19 125:4
136:13 136:16 143:12

accepts,25:22
164:25
agreement. ( 21 ) 10:9
annexed ( 3 ) 46:12
125:12 125:20 126:1
144:10 149:1 150:4

accessibility,115:14
adopt151:6
19:11 20:13 20:14
48:15 49:5
126:11 126:19 127:5
150:23 151:13 151:15

accommodate ( 4 ) 72:9
adopts25:20
20:16 32:25 37:8
another ( 23 ) 14:1 15:7
127:8 153:14 153:20
151:16 151:17 151:23

144:7 157:25 163:14
advance ( 5 ) 37:22
39:19 55:14 61:20
18:4 19:18 21:6 22:8
applications161:16
152:19 152:24 153:3

accommodating,157:23
37:22 39:15 78:21
63:23 64:18 64:22
24:15 32:9 57:7 86:11
applied ( 4 ) 7:21
153:5 155:13 160:9

accompanied ( 2 ) 177:19
86:8 87:3 88:12 88:15
86:16 86:24 87:19
108:21 117:25 128:17
160:14 160:17 164:21

83:24 125:19
advanced ( 2 ) 104:23
118:3 118:16 118:17
88:11 91:16 99:22
apposite67:3
168:2 169:12 169:17

accompany83:22
127:22
118:19
101:16 113:23 115:1
appreciate ( 10 ) 2:24
170:8 170:23 171:17

accord35:7
advancing ( 3 ) 93:24
agreements ( 20 ) 9:6
130:24 137:21 149:23
4:25 5:20 8:11 78:9
171:23 172:15 174:3

accordance ( 7 ) 26:7
119:22 120:19
10:22 11:4 14:6 14:11
172:24
84:4 85:7 94:9 94:10
174:19 178:3 178:4

49:13 53:8 58:10
advantage ( 2 ) 69:13
15:2 16:8 17:11 18:2
answer. ( 13 ) 22:12
131:25
Arkhangelsky’s ( 11 )
114:16 138:7 147:12
137:21
20:18 20:19 38:2
43:13 44:23 45:4
apprised52:24
42:1 52:18 54:14 55:8

according ( 5 ) 32:25
advice, ( 3 ) 138:13
51:14 55:17 64:13
45:21 48:7 48:11
approach ( 4 ) 22:17
62:7 83:23 90:6 92:7

36:5 58:21 89:23
139:7 139:9
65:19 67:15 111:9
95:19 117:13 124:22
22:20 25:16 149:18
122:14 143:20 144:20

133:16
advised ( 3 ) 106:4
118:1 139:10
124:23 139:22 140:8
appropriate ( 9 ) 1:24 arose. ( 2 ) 35:25 36:3

accordingly, ( 3 ) 138:12 139:6
agrees ( 2 ) 124:7
answered ( 4 ) 36:16
10:16 47:20 47:24
around ( 8 ) 2:25 53:15

117:24 118:19 137:13
advisement3:8
163:10
95:21 95:21 119:10
66:2 74:17 131:22
53:17 56:5 62:9 82:19

account ( 7 ) 3:2 3:24
advisers,175:4
ahead ( 5 ) 2:12 5:12
answering132:11
145:18 148:6
84:21 168:5

115:13 130:23 153:10
advisory ( 2 ) 104:15
52:2 76:24 112:13
answers ( 7 ) 6:8 25:21
approvals ( 2 ) 16:14
arrange ( 4 ) 36:1 67:8

153:15 153:16
106:25
aide-memoire, ( 3 ) 43:17 79:25 101:14
16:17
119:23 120:20

accounting41:9
advocate,155:20
177:14 177:22 177:25
102:5 144:15
approvalship;16:9
arranged ( 3 ) 99:17

accounts ( 5 ) 17:8
affects41:1
aim74:9
anticipate ( 2 ) 9:19
approve118:12
109:6 109:16

55:20 147:16 153:24
affidavit ( 6 ) 52:25 53:3
aiming75:22
43:23
approved ( 6 ) 109:18
arrangement ( 2 )
154:10
53:7 54:2 54:14 54:18
alerted156:11
anticipated ( 2 ) 9:1
109:20 111:24 112:23
119:20 169:16

accredited ( 6 ) 107:1
(Affirmed) ( 4 ) 79:24
alia152:12
44:4
113:24 116:19
arrangements ( 8 )
107:9 107:11 107:13
102:4 179:13 179:21
allegation, ( 3 ) 25:11
anticipates123:16
approximately ( 2 ) 44:6
17:10 65:2 67:11

107:14 114:10
afforded ( 2 ) 164:9
98:24 144:22
anxious, ( 2 ) 2:11 98:1
82:23
71:18 96:3 96:8 96:9

accrued137:13
164:11
alleged ( 5 ) 30:8 34:4
anybody139:15
April, ( 13 ) 31:11 31:11
96:15

accruing36:9
afraid ( 23 ) 1:7 21:23
144:17 144:18 155:7
anybody’s169:6
35:13 35:22 36:6
arranging38:7

accumulated,62:20
52:20 75:3 81:20
alleging19:14
anyone ( 13 ) 17:21
36:10 36:24 53:15
arrears, ( 10 ) 17:6 17:9

accurate ( 2 ) 51:19
81:24 82:7 83:4 84:8
allow ( 7 ) 72:25 73:21
19:16 20:5 23:13
53:17 53:22 55:5
18:23 30:15 31:16

122:10
87:10 88:13 95:7
152:19 152:20 160:10
29:1 29:10 29:22
56:17 57:14
42:9 58:25 59:3 59:22

accurately150:15
99:24 101:10 107:20
163:15 175:18
68:4 83:22 95:6 113:5
aptitude166:18
60:4

achieved17:11
109:2 113:2 114:1
allowed ( 5 ) 2:6 14:14
129:17 154:17
archive32:7
arrive82:6

achieves169:16
118:22 123:11 148:10
23:8 28:13 99:2
anything ( 39 ) 3:14
archiving32:14
arrived82:17

acknowledge113:16
148:16 148:20
almost ( 6 ) 1:16 23:24
3:15 4:25 5:3 17:10
area ( 5 ) 52:4 89:11
ascertain ( 3 ) 63:12

acknowledged,26:5
after ( 27 ) 14:15 15:4
92:8 122:3 148:18
19:5 22:25 23:11 30:3
89:12 90:13 95:8
77:23 126:5

across157:12
30:7 31:19 33:2 72:13
163:6
36:4 37:15 43:5 45:5
aren’t56:17
ask ( 31 ) 13:5 21:17

action149:17
72:18 74:2 74:17
alone91:6
48:13 52:14 63:16
arguably97:25
23:25 30:7 40:21

active36:24
77:22 78:2 82:9 82:13
along ( 4 ) 44:6 106:9
78:20 82:1 83:6 83:20
argument116:8
41:12 43:24 45:19

activities.131:20
82:15 82:17 86:11
145:5 176:7
90:5 91:3 91:4 92:16
arise, ( 4 ) 60:5 142:23
48:20 49:18 70:19

actual ( 11 ) 7:22 7:22
86:16 88:10 94:20
already ( 7 ) 8:17 20:18
93:7 94:24 94:25
145:6 170:10
79:1 79:4 79:5 88:17

11:1 16:7 33:16 41:11
113:2 132:21 135:5
24:12 63:10 84:17
95:3 95:6 106:9 113:9
arisen5:2
88:19 94:24 95:6 95:8

47:18 47:22 49:24
150:14 161:15 161:22
168:20 170:9
126:9 135:23 137:15
arising ( 3 ) 68:4 68:17
95:10 96:2 103:8

60:14 125:4
164:1 167:1
also ( 32 ) 11:7 14:8
148:21 151:5 154:8
68:20
119:3 124:16 129:3

added170:6
afternoon. ( 7 ) 55:13
15:7 26:21 31:1 32:6
155:20 174:14
Arkhangelskaya, ( 11 ) 132:6 132:20 132:25

addenda, ( 2 ) 20:17
77:3 81:9 82:9 103:10
33:3 33:24 34:19 35:2
Anyway, ( 3 ) 67:10
23:8 23:13 25:25 26:7
136:22 138:4 160:10

40:6
112:15 146:7
50:6 55:1 59:5 60:2
92:4 95:10
130:19 131:6 132:8
asked ( 36 ) 4:1 14:10

adding48:25
afterwards, ( 2 ) 132:22
64:12 73:14 91:11
anywhere ( 2 ) 22:2
132:13 168:13 171:12
18:11 28:22 29:2 29:6

addition ( 2 ) 7:4 96:12
162:3
94:4 106:16 110:4
58:23
174:24
29:7 29:19 30:22

114:1 119:18 130:18
33:22 41:25 42:6

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43:12 43:14 44:1 44:5 45:10 45:11 45:17 46:7 60:16 60:20 63:23 65:13 68:25 70:9 75:4 92:17 119:9 125:4 141:2 146:1 155:13 155:20 175:8 176:3

asking ( 17 ) 8:15 9:17 9:18 13:17 23:20 38:1 43:2 69:11 86:20 96:12 97:16 104:25 113:4 117:14 118:6 127:19 170:20

aspects50:24 aspirations161:2 assert ( 3 ) 85:22 87:6
138:2

assertion, ( 3 ) 38:10 68:1 121:7

assess104:5 assessing132:2 assessment ( 2 ) 11:22
118:8

asset ( 2 ) 145:2 156:17 assets ( 10 ) 110:5

119:24 119:25 120:2 120:3 120:21 121:4 121:7 121:12 121:13

assigned32:9

assist ( 9 ) 5:10 10:24 15:12 83:17 107:15 154:15 155:8 156:4 173:10

assistance ( 2 ) 104:19 104:25

assistant,30:18 assists.74:25 associated ( 2 ) 53:23

107:9 assumption,68:1 assure8:14 attach33:24

attached ( 3 ) 44:7 54:2 56:16

attachment ( 4 ) 55:22 55:23 57:15 106:2

attachments, ( 2 ) 56:16

56:20

attempt ( 2 ) 48:8

174:14 attempted84:7

attend ( 5 ) 25:25 96:13 131:6 146:2 169:19

attendance.143:4 attending, ( 2 ) 96:19
144:12

attention ( 8 ) 10:21 11:8 47:18 106:8 117:18 124:5 124:25 126:24

attentively86:8 auction. ( 2 ) 10:7 10:10 audio ( 6 ) 167:4 167:5

167:22 168:7 169:2 173:19

audit ( 2 ) 42:3 42:16

August ( 3 ) 80:21 102:22 134:21

authentic, ( 3 ) 29:23 29:24 30:2

authorised19:10 authorities?43:10 automatically ( 2 )

15:25 17:5 autumn47:15 available ( 15 ) 33:19

62:15 105:19 109:2 118:25 126:2 163:11 168:11 169:9 170:25

171:4 174:2 174:3 174:11 175:3

Avenue,62:18 avenues ( 2 ) 172:10

172:11 avid171:3

avoid ( 4 ) 128:12 137:18 152:22 164:21

avoided4:21

aware ( 12 ) 61:12 63:7 64:24 79:4 81:11 99:12 101:9 105:5 114:2 129:8 132:7 133:13

away ( 5 ) 6:6 71:19 91:16 94:5 99:1

awfully71:18

B

{B1/6/15}.130:10 {B1/6/2} ( 2 ) 130:2
130:5

{B1/6/3}.130:12 {B1/6/5}.131:4 {B1/7/13}, ( 2 ) 134:2
134:11

{B1/7/35}134:13 {B2/10/6},80:12 {B2/10/8},80:20 {B2/11/13},136:24 {B2/11/16},102:21 {B2/11/4} ( 3 ) 128:1

128:3 138:6

{B2/11/5}.136:24 {B2/11/9}.102:13 {B2/9/13},13:20 {B2/9/16}:58:3 {B2/9/19},45:8 {B2/9/36}.13:20 {B2/9/43},45:14 {B2/9/8}.63:6 {B2/9/9},64:9

back ( 31 ) 15:17 32:16 33:16 34:17 34:24 35:14 43:16 54:5 56:8 56:9 56:14 61:17 62:12 63:9 69:8 71:11 71:21 72:14 73:8 84:5 96:20 99:3 101:2 106:7 123:10 138:4 144:24 158:20 160:6 173:23 174:7

backdate ( 2 ) 28:23 29:9

backdated ( 6 ) 13:15 16:23 17:2 18:3 28:2 135:3

backdating ( 5 ) 16:19 18:18 132:3 132:24 134:3

background177:24 bad ( 5 ) 22:12 45:25 46:1 46:10 88:14 badly, ( 2 ) 11:15 41:6

bailiwick,173:14 balance. ( 6 ) 15:24

17:7 19:1 58:25 111:8 165:3

Bank ( 170 ) 3:2 3:13 3:15 3:22 3:23 4:25 6:25 7:8 7:14 7:15 7:25 8:24 9:16 9:25 10:8 10:8 10:11 10:14 10:25 11:4 11:10 11:17 11:25 12:15 17:25 18:5 18:5 18:13 18:13 18:15 19:2 19:9 19:10 19:11 23:9 23:9 26:3 27:22 28:6 28:10

29:22 34:19 35:12 35:24 36:12 36:15 39:22 40:4 40:19 40:20 40:23 41:5 41:10 41:18 41:24 42:14 42:16 48:9 49:19 51:25 53:17 53:22 58:11 59:8 59:9 59:10 59:10 61:21 62:15 63:15 63:19 67:12 72:21 76:5 77:22 81:15 82:11 87:16 92:11 92:18 93:22 94:10 96:4 96:8 98:21 98:25 103:20 103:24 104:2 105:4 105:7 105:9 105:16 106:4 107:1 107:2 107:10 107:12 107:16 107:17 108:2 108:8 108:22 108:23 110:2 110:7 110:22 111:5 114:6 114:8 114:10 114:12 114:22 115:2 115:2 116:1 117:8 119:19 119:23 120:4 120:20 121:20 122:2 122:3 122:4 122:6 122:13 123:10 123:25 124:7 124:9 125:3 125:22 126:10 126:20 127:7 128:8 130:23 130:24 130:24 131:7 131:9 131:13 137:8 138:16 138:24 139:14 145:13 145:19 147:14 147:22 147:22 150:13 153:14 153:16 153:17 153:23 154:5 154:24 155:1 155:3 155:5 155:8 155:14 155:18 155:21 156:8 158:15 158:18 161:9

Bank’s ( 14 )12:4 33:22 37:19 37:20 38:5 107:3 114:17 136:1 137:13 137:20 138:7 138:19 139:2 139:8

banking ( 4 ) 16:21 30:13 69:11 131:19

banks. ( 3 ) 38:2 59:12 64:13

base145:2

based ( 4 ) 14:9 127:7 153:11 166:25

Basically ( 2 ) 117:14

125:7

basis ( 8 ) 24:4 25:11 27:5 33:5 36:25 52:1 75:4 135:12

baton100:19

battle ( 2 ) 147:2 163:7 battles.163:7 bearing100:8 became14:1

become ( 2 ) 101:14 113:14

becomes159:12 before ( 14 ) 11:2 11:11

53:10 69:17 73:24 82:11 116:22 119:22 120:19 146:19 149:19 160:23 161:25 167:1

beg ( 9 ) 13:2 27:23 42:21 101:8 117:12 126:17 127:24 136:17 144:14

beginning ( 2 ) 144:16 153:21

begins123:19

behalf ( 3 ) 35:23 48:9 93:10

behind ( 9 ) 3:9 50:14 66:6 66:8 84:22 91:22 102:2 141:7 172:10

belief? ( 4 ) 81:3 81:5 103:4 142:19

believe ( 19 ) 17:20 18:24 19:9 19:12 20:15 30:1 40:15 53:7 67:19 69:3 81:24 82:8 91:5 95:3 111:19 113:5 131:8 146:15 146:22

believed, ( 3 ) 30:1 42:5 107:2

believes142:13 bells?92:9 belonging83:15 Belykh. ( 5 ) 105:24

129:19 129:20 129:22 130:17

bend144:7 beneath.55:1 benefit ( 2 ) 18:20
109:11

Berezin31:5 beset173:5

best ( 13 ) 5:11 73:7 75:3 81:2 81:4 97:12 98:10 103:3 108:20 109:13 148:13 150:10 166:19

better ( 6 ) 68:13 77:12 119:3 134:14 172:17 175:22

between ( 23 ) 1:15 8:9 14:8 14:24 19:1 19:11 20:20 30:12 35:6 55:18 58:23 69:22 82:24 96:8 122:1 149:2 153:17 156:7 163:12 169:19 170:23 171:22 175:9

beyond ( 2 ) 96:2 159:23

Bidault? ( 3 ) 143:16 148:15 155:21

big ( 3 ) 76:20 145:21 158:20

Birt. ( 18 ) 166:17 166:18 167:4 168:4 169:1 170:6 170:13 171:5 171:10 172:4 172:6 172:22 173:5 173:9 173:13 173:23 174:16 174:19

bit ( 16 ) 25:8 31:20 44:15 56:5 77:19 79:13 132:17 141:21 146:22 158:6 161:18 167:1 167:1 169:18 171:23 176:24

bits ( 2 ) 25:3 25:4 BKK ( 3 ) 124:4 124:19
127:1

Blagodatnaya62:1 blind129:2

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53:13 53:25 54:13 54:16 55:22 56:2 56:3 56:12 56:15 57:11 67:11 70:14 71:7 71:9 71:19 111:16 112:7 112:25 113:3 113:6 113:11 114:1 179:4

Blinova’s69:13. blocked147:16 blush?75:1

board ( 9 ) 41:18 50:4 50:9 50:17 51:25 66:10 66:21 74:12 124:5

board’s50:25 bob25:8

bodies, ( 3 ) 43:1 48:1 124:7

body ( 3 ) 19:10 43:3 59:10

booked167:1 Borisova, ( 2 ) 16:16

111:17 borrowed5:14 borrower ( 9 ) 14:4

32:19 32:23 37:25 61:16 63:14 64:13 103:21 110:3

borrowers, ( 6 ) 30:10 34:2 58:1 58:5 104:24 137:10

boss,17:19

bosses ( 12 ) 18:9 19:4 22:19 23:14 23:20 24:7 24:17 25:2 26:9 26:20 27:2 27:16

Both ( 10 ) 6:22 7:6 70:10 72:9 73:21 77:6 103:24 117:21 169:19 171:8

bother ( 3 ) 40:12 41:11 130:13

bottom ( 6 ) 39:14 66:24 102:16 115:5 115:12 145:21

bounced149:17 bound ( 2 ) 149:7
149:13

box. ( 7 ) 1:17 49:23 102:2 159:2 168:12 172:23 173:1

brackets46:14 brains57:24

branch ( 8 ) 16:15 59:1 104:17 110:21 129:16 129:16 133:18 135:6

branch’s ( 2 )133:18 135:10

branches110:23 breach, ( 3 ) 18:25

19:12 19:13 break, ( 23 ) 3:11 4:5

4:13 38:20 38:23 38:25 39:3 79:6 80:3 82:9 82:13 82:14 82:16 82:19 88:17 89:6 101:23 103:1 137:17 143:7 144:1 163:11 163:13

breathing23:18 brief.154:13

briefly ( 6 ) 6:12 22:24 37:19 43:16 116:15 153:3

bright92:8

bring ( 2 ) 76:23 89:18 broad ( 2 ) 25:11 25:13 brought ( 7 ) 85:2 97:19 120:6 121:22 124:5
124:25 126:24 BSP50:9

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building ( 15 ) 83:2 83:7 83:10 83:15 83:16 84:9 89:12 89:13 90:14 90:17 90:17 90:18 90:20 160:24 172:8

buildings,89:13 bunch ( 2 ) 33:8 62:23 bundle ( 11 ) 46:2 50:12

50:14 65:11 66:9 80:10 80:19 112:3 140:24 141:17 176:7

business ( 13 ) 12:12 104:25 105:1 105:10 105:18 106:21 107:4 107:15 108:2 108:7 160:22 162:13 164:12

busy25:24

BVI ( 4 ) 53:1 54:14 54:18 56:8

bye ( 3 ) 160:16 160:16 160:17

C

{C1/5/4}.119:2 {C1/9/4}.107:23

C2188:5

C2287:25

calculate ( 2 ) 6:23 7:1 calculating137:18 calendar14:2

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called ( 11 ) 21:4 36:13 39:7 90:25 92:19 97:10 103:16 109:24 114:16 116:12 119:5

calling73:13

calls ( 3 ) 23:19 23:21 168:1

Cambridge ( 2 ) 97:18

99:3

camera ( 2 ) 172:9 172:24

cameras.171:24 can’t ( 23 )4:3 4:8 8:18

21:8 50:23 50:25 65:19 75:2 75:23 85:9 92:16 99:1 99:25 145:3 145:7 145:11 151:20 156:19 162:10 163:7 171:6 171:8 172:13

cannot ( 16 ) 10:11 11:13 32:24 43:7 62:2 67:14 85:22 89:10 125:24 131:7 135:24 138:2 147:2 149:1 154:8 157:1

capacity19:8

car, ( 19 ) 81:13 81:18 81:21 81:22 82:1 82:2 82:4 89:17 89:21 89:22 89:24 90:1 90:2 90:3 90:6 90:8 94:1 94:1 94:5

card ( 3 ) 69:7 69:8 130:23

cards,94:2 care,8:17

careful ( 2 ) 119:23 120:20

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carefully ( 8 ) 42:11
112:17 114:22 115:21
comments ( 2 ) 108:10
conference166:20
contextualise40:14

125:15 148:9 150:2
147:25
119:21
conferred,61:18
(Continued) ( 5 ) 6:7

150:13 153:2 156:11
cited10:22
commercially ( 2 ) confidence107:18
6:10 36:6 179:5 179:7

157:13
claimants’ ( 4 )109:5
120:7 121:23
confirm ( 15 ) 21:19
continues121:2

carried42:13
109:6 109:12 170:20
commit161:21
55:3 81:1 81:4 94:7
contract ( 9 ) 40:6 40:7

carry ( 4 ) 14:14 110:2
claims11:2
committed150:11
94:16 102:18 103:2
40:13 40:17 40:22

114:8 115:3
clarify ( 3 ) 31:17 46:5
committee ( 4 ) 16:15
103:5 110:16 125:24
41:1 106:3 108:19

cases, ( 3 ) 7:8 12:14
134:25
123:22 127:1 135:6
127:17 131:7 150:24
108:24

37:24
clause131:1
committees. ( 2 ) 66:10
151:22
contracts, ( 8 ) 20:11

categorically12:15
clean32:6
134:4
confirmation ( 5 ) 25:20
20:11 24:23 28:8

categories58:20
clear ( 16 ) 19:14 22:14
communicate ( 2 ) 33:23 48:2 108:21
28:16 40:2 50:12

caught89:14
44:23 45:4 70:3 77:7
122:9 167:24
139:18
65:11

cause ( 3 ) 3:16 4:21
78:11 84:9 101:14
communication ( 4 ) confirmed ( 3 ) 70:10
contractual16:7

148:22
104:20 113:14 147:9
4:6 154:23 155:1
71:2 78:22
contradict8:4

caused ( 2 ) 149:3
151:16 151:17 159:12
155:7
confirming24:16
controlled ( 2 ) 60:15

150:17
173:2
communications149:2
conform138:24
68:7

causes149:20
clearer137:5
companies ( 15 ) 30:21
confused ( 2 ) 69:12
convenient ( 3 ) 2:17

ceasing137:3
clearest5:16
49:20 103:19 105:3
170:19
4:11 4:13

cent ( 3 ) 58:23 116:2
clearing99:1
106:25 107:2 107:9
confusing. ( 2 ) 34:5
conversation ( 5 ) 119:8

116:5
clearly ( 10 ) 5:8 28:15
107:13 107:14 114:9
91:1
120:10 127:10 127:15

Central ( 8 ) 18:15 41:10
30:17 34:22 77:24
114:14 116:7 119:20
confusion ( 3 ) 30:12
127:18

58:11 59:8 59:8 59:10
85:3 88:6 89:20
122:21 137:9
69:2 69:3
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59:10 137:8
148:12 172:20
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conjunction,156:3
cooperation. ( 2 ) 104:6

certain ( 12 ) 10:8 27:10
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55:16 55:19 67:1
connected ( 2 ) 92:21
169:18

28:15 29:16 35:22
150:12
103:16 103:18 105:17
137:21
copied1:10
40:4 40:18 42:22
click ( 2 ) 46:16 173:21
106:20 108:18 111:1
connection ( 4 ) 13:9
copies. ( 8 ) 23:10 61:24

114:17 124:9 133:16
client ( 30 ) 13:9 15:9
114:15 115:1 115:20
13:13 80:16 102:19
85:10 109:9 140:17

137:12
17:22 18:12 18:20
123:3
conscientiously,158:20
166:8 175:5 176:4

certificate26:4
18:21 19:2 19:4 19:11
Company’s122:24
conscious ( 5 ) 8:3 74:5
copy, ( 19 ) 21:23 22:2

certificates,111:9
20:23 24:8 29:19
compared116:20
124:15 160:22 160:24
22:5 22:6 22:12 22:14

certification,23:1
29:20 33:20 33:24
competence.43:13
consent ( 18 ) 25:15
29:2 62:15 66:16

certified22:17
42:9 59:19 105:19
competent108:6
26:1 27:18 61:23
66:17 80:9 87:25

certifies,18:5
114:25 123:24 124:6
complain.163:2
130:21 130:25 131:8
102:14 109:12 126:25

certify18:6
125:1 125:2 125:4
complaint.153:2
131:10 131:12 132:9
143:23 155:5 155:6

chairman ( 2 ) 158:15
126:20 126:24 127:3
completed,97:19
138:9 138:15 138:18
166:1

158:18
129:8 129:9 129:15
completely ( 4 ) 108:4
138:21 139:4 139:13
core176:7

challenged25:12
client’s123:15
147:17 157:20 174:16
140:13 141:7
corner23:15

chance ( 5 ) 1:8 90:9
clients, ( 12 ) 15:8 18:16
completeness,107:19
consents, ( 2 ) 61:22
corporate ( 6 ) 30:10

152:24 153:1 154:16
31:3 31:23 31:23
complex, ( 2 ) 58:19
138:11
32:23 34:2 61:15

change ( 10 ) 88:22
103:20 104:11 104:24
130:9
consequences147:18
125:9 125:17

88:25 114:23 114:24
105:6 107:10 144:18
complexity166:19
consequently147:15
corporates7:6

115:16 125:4 154:2
164:7
compliance55:17
consider ( 10 ) 74:2
correct? ( 25 ) 6:17 10:5

155:2 161:21 171:6
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composed?117:17
74:21 77:10 77:14
13:10 13:11 16:10

changed ( 8 ) 3:17 15:2
142:5
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150:13 158:6 158:11
19:19 31:7 32:10

82:25 84:24 124:8
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compromise ( 2 ) 98:19
159:23 161:14 161:15
34:17 35:9 35:10

124:11 125:3 125:3
closing. ( 3 ) 160:9
114:22
considerably ( 2 ) 116:5
49:15 51:3 51:12

changes ( 5 ) 16:3
160:11 160:14
compromises131:18
162:18
81:14 85:3 85:13

16:25 17:3 47:14
coefficient ( 2 ) 116:8
compulsory125:8
considerations165:4
88:23 96:6 105:6

132:19
117:25
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considered ( 3 ) 64:23
114:3 121:14 125:15

changing150:16
collaboration,170:15
15:14 15:19 15:23
64:25 158:7
126:23 145:13

channel ( 4 ) 167:5
collateral, ( 7 ) 6:24
16:3 17:4
considering12:10
corrected ( 10 ) 48:25

167:11 167:15 171:2
7:7 8:10 11:6 110:10
computers,15:2
considers7:15
49:13 52:8 63:3 63:5

chaotic, ( 2 ) 152:1
114:20 118:4
conceal ( 3 ) 48:9 48:12
consistent ( 3 ) 47:17
63:9 87:11 125:16

157:8
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47:22 130:14
144:21 146:18

characteristic89:19
colour ( 5 ) 84:10 90:3
concern. ( 10 ) 113:18
constantly,169:11
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charge ( 5 ) 17:18 30:19
91:8 92:8 92:10
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30:20 60:21 93:24
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charges ( 2 ) 120:6
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150:18 174:4 174:23
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121:22
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check ( 8 ) 45:5 111:7
47:18 52:18 62:8
16:6 18:12 18:18
106:5 107:9 108:3
30:20 30:22 156:7

115:6 142:9 142:17
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33:13 38:24 60:24
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checked ( 4 ) 67:7 70:9
119:2 140:7 144:24
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166:23 168:15 168:20

111:3 147:4
156:19 158:19 159:9
163:19
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checking ( 5 ) 23:1
159:13 161:13 161:16
concerns ( 4 ) 97:15
92:13 147:21 155:21
couldn’t ( 3 )95:13

62:14 109:24 110:5
172:16 176:20
112:7 144:9 171:19
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146:17
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concluded ( 2 ) 53:5
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cheques ( 6 ) 3:4 3:5
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3:6 76:5 147:19 151:3
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conclusion ( 3 ) 41:17
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child96:20
coming ( 10 ) 3:19 4:4
93:9 115:15
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childcare169:21
36:1 69:8 76:22 84:13
conclusions, ( 2 ) 41:16
contained ( 2 ) 47:5
8:20 9:23 9:23 9:25

children.96:20
106:7 133:6 145:5
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choice ( 2 ) 167:6 167:7
160:5
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choose ( 4 ) 159:21
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41:3 127:6
content? ( 5 ) 99:12
74:7 101:3 113:14

159:22 167:11 167:15
commend ( 2 ) 44:16
conditions, ( 9 ) 32:25
142:23 143:1 157:5
117:12 124:12 125:2

chronology ( 3 ) 16:22
141:21
40:3 40:19 41:2 41:19
174:9
132:1 144:23 151:9

62:2 94:20
comment ( 9 ) 94:17
124:8 124:10 125:3
contents ( 4 ) 81:2 81:5
155:10 156:25 175:2

circulation,7:4
106:13 108:11 108:13
127:6
102:24 103:3
cover ( 6 ) 4:3 6:24

circumstances. ( 7 ) 115:24 115:24 120:15
conduct42:17
context ( 8 ) 62:4 64:10
10:11 52:4 100:17

83:1 93:11 105:13
121:25 134:19
conducted, ( 2 ) 42:3
65:2 65:3 70:2 70:3
101:4

42:18
139:4 164:24
coverage7:2

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covered7:2 covering100:18

crack ( 2 ) 98:19 101:22 create29:8

created ( 3 ) 58:10 58:13 59:21 credibility.132:3

credit ( 19 ) 14:6 15:6 16:14 17:18 39:12 93:22 94:2 110:7 110:8 110:24 114:17 118:3 123:22 126:3 127:1 130:22 135:5 139:17 141:24

crediting110:1 creditor32:20 criminal ( 2 ) 120:6
121:22

crisis, ( 2 ) 120:3 121:13 critical ( 2 ) 17:24 70:9 criticise24:6 cross-examination,

( 19 ) 1:6 2:20 5:13 6:2 6:10 44:15 68:22 77:12 79:7 81:8 95:11 100:15 103:9 157:11 179:6 179:10 179:15 179:17 179:23

cross-examinations ( 2 ) 75:5 148:19

cross-examined172:20 cross-

examining,172:15 cross-reference109:15 crossed62:13 crystallised.150:18 current ( 4 ) 114:25

153:10 153:15 158:15 currently73:14

cut ( 2 ) 23:15 157:11 cut-out63:22

D

{D1/2/19},39:8 {D1/2/9}39:8

{D117/1737/1} ( 3 )

55:21 55:24 56:14

{D117/1737/2}.57:2 {D117/1737/3}57:9 {D117/1737/4}. ( 2 ) 56:2
56:6

{D117/1737/5}.57:5 {D117/1737/6}57:8 {D118/1796/0.1}.54:3

{D118/1796/9}. ( 2 )

54:16 56:10

{D12/262.1/0.16}. ( 2 )

140:16 141:8

{D13/288/1},122:18 {D13/288/2},123:1 {D13/288/3}.122:19 {D13/288/4}.123:1

D22 ( 2 ) 117:19 118:2

{D22/423/0.1}.116:17 {D22/423/1},116:15

D32 ( 2 ) 117:19 118:2

{D32/512/0.1},117:3 {D32/512/1}.117:2 {D34/537/1},103:14 {D34/537/15}106:1 {D34/537/2}.103:15 {D34/537/3}105:25 {D36/615/1} ( 4 ) 50:6 50:16 66:15 66:18

{D36/615/4},50:7 {D40/691/1}21:2 {D40/691/2}21:3 {D41/737/1},22:7 {D41/737/2}.22:8

D44 ( 2 ) 117:23 118:3
decision, ( 14 ) 38:4
detail ( 9 ) 8:6 16:11

{D44/772.1/0.1} ( 2 ) 64:20 124:7 126:25
67:22 78:17 84:25

113:20 115:10
127:2 127:4 127:5
87:7 88:8 91:17

{D44/772.1/0.2}.115:9
127:23 133:9 133:18
131:17

{D44/772.1/1},113:20
135:7 137:17 169:15
detailed124:14

{D5/122/1}.46:18
170:1
details. ( 13 ) 40:4 47:16

{D5/123/1}.46:19
decisions ( 6 ) 28:5
83:4 84:8 90:4 90:11

{D5/123/5}.46:23
37:21 124:25 133:8
90:19 90:19 91:23

{D5/124/1}46:18
135:3 135:5
98:23 98:24 124:24

daily ( 5 ) 3:4 33:5
declarations ( 2 ) 18:5
144:23

135:12 153:15 173:20
25:15
detained71:10

dangers:149:9
deemed138:22
detected, ( 3 ) 63:8

dare154:16
default, ( 4 ) 7:15 30:8
63:11 87:22

dark95:15
35:8 60:1
Detection…87:25

dash,64:5
defaults30:8
detracts164:25

date ( 11 ) 28:17 29:5
defendants, ( 4 ) 5:9
develop ( 2 ) 108:1

58:12 80:21 80:22
54:7 147:16 177:7
108:6

116:19 133:5 133:8
defer78:3
development ( 2 )
133:9 133:12 135:8
deference149:18
165:20 165:23

dated ( 9 ) 18:4 31:10
deferred,4:10
didn’t ( 20 )29:23 32:11

53:22 55:15 102:22
definite.120:12
33:17 43:20 45:10

111:6 116:14 116:25
definitely ( 8 ) 82:3
47:5 49:1 52:6 63:16

117:5
82:11 83:18 104:23
71:5 109:19 111:20

dates ( 5 ) 20:15 32:24
123:14 124:25 127:16
113:6 113:11 119:12

118:17 135:11 165:15
170:22
128:7 140:7 149:6

day ( 38 ) 9:9 11:13 14:3
degree ( 2 ) 86:22 144:8
157:11 158:16

18:4 18:4 23:24 33:11
delay15:25
differ.27:23

33:12 33:12 72:19
delayed55:14
difference ( 2 ) 8:9

72:20 77:3 82:5 97:11
delaying166:11
167:20

98:4 98:17 100:9
delete ( 2 ) 32:12 49:11
different ( 21 ) 6:20 8:16

104:8 106:20 108:15
deleted ( 4 ) 31:25
12:6 18:1 30:8 51:4

108:17 156:20 161:24
32:13 32:14 49:8
90:7 91:25 92:2 92:4

163:15 163:16 163:20
deliberate153:2
93:25 117:23 117:24

163:22 166:24 166:24
deliberately157:14
118:1 118:17 119:21

166:25 168:16 168:21
deliberation150:14
146:15 146:16 161:23

170:14 171:10 173:15
deliver33:17
163:8 165:15

175:12 175:16 175:18
deliverables108:16
differently,175:17

{Day5/13:15}.69:21
delivered ( 3 ) 33:15
difficult ( 7 ) 3:23 70:24

days ( 20 ) 9:8 59:2
34:23 60:18
71:20 77:19 90:11

59:3 59:4 59:13 59:17
delivery, ( 7 ) 30:11
94:19 164:24

73:12 73:17 100:10
34:1 34:3 34:6 34:9
difficulties170:16

152:16 158:9 158:10
34:15 60:17
difficulty ( 4 ) 78:24

158:11 159:5 159:5
demand ( 7 ) 12:16 30:9
90:22 112:4 144:11

159:15 159:16 159:17
52:6 56:21 57:15
diligence.» ( 3 ) 51:18

160:22 171:12
61:25 170:25
51:23 66:25

deal ( 15 ) 5:19 47:9
demanded ( 2 ) 120:5
direct ( 8 ) 38:2 39:19

67:9 72:24 76:4 77:21
121:21
55:19 61:18 64:12

77:23 79:22 144:8
demanding ( 2 ) 53:18
64:18 64:22 65:1

144:12 146:3 149:21
138:17
directed ( 2 ) 69:1

151:10 151:18 156:2
demands ( 6 ) 33:1 60:7
129:22

dealing ( 5 ) 129:18
60:10 60:11 60:25
directly ( 5 ) 34:18

145:25 150:2 151:7
61:6
35:20 37:8 129:9

156:4
denied.3:24
155:21

dealings104:6
deny12:15
director ( 8 ) 31:14 48:5

dealt ( 5 ) 4:22 9:8
department, ( 16 ) 8:7
57:1 111:16 114:4

129:13 147:7 152:12
15:6 23:24 28:11
134:20 154:4 154:25

debated142:10
29:18 32:1 42:3 42:13
directorate110:23

debit ( 6 ) 38:2 39:19
42:16 63:11 92:18
disagree, ( 4 ) 9:5 27:23

64:12 64:18 64:22
92:19 93:23 110:1
41:15 93:7

65:1
110:24 131:11
disagreed106:12

debits55:19
departments133:19
disburse28:14

debt ( 9 ) 36:9 43:18
depend ( 2 ) 63:13
disbursed ( 2 ) 24:2

45:11 45:17 45:25
161:18
28:13

46:1 58:16 59:14
depended82:20
discard20:21

59:22
depending83:1
disclosed ( 8 ) 31:7

debtors,58:21
depends ( 2 ) 98:7
125:18 125:21 126:6

debts. ( 6 ) 7:23 9:9
98:11
141:16 141:19 141:19

46:10 55:14 59:18
depict149:6
156:23

59:20
deposed53:14
disclosure ( 5 ) 34:1

December ( 16 ) 13:15
deposit153:6
43:18 54:7 101:21

13:25 14:2 14:3 14:13
describe ( 4 ) 28:9 83:2
109:5

15:5 15:10 16:13
84:3 84:14
discount ( 6 ) 114:18

16:20 16:24 17:1
described59:25
114:23 115:25 116:2

17:2 17:3 18:3 116:25
describing ( 2 ) 14:6
116:4 117:22

117:5
166:19
discovered108:3

December/early13:6
description84:9
discrepancy67:9

decide ( 2 ) 3:11 124:6
designed138:24
discuss ( 8 ) 4:12 31:12

decided ( 2 ) 41:17
desirable9:20
76:3 76:6 77:5 109:3

153:22
desire159:24
154:17 170:18

decides40:23
despite175:20

destroy20:21

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discussed ( 6 ) 11:21 18:8 23:6 24:12 24:23 128:15

discussing ( 2 ) 117:23 175:9

discussion ( 3 ) 46:10 99:9 171:22

dishonoured,3:5 dishonouring147:19 disk174:13 dispatch74:9 disposal89:17 dispute ( 6 ) 8:3 35:25

36:2 54:8 122:1 157:16

disrespect ( 2 ) 14:17 142:18

disrespectfully,160:25 disseminated ( 2 )

174:5 174:10 dissemination174:12 distinct ( 2 ) 40:7 60:10 distinction.67:5 distracted,22:22 disturbed.2:4

divider ( 6 ) 50:14 66:8 66:15 80:11 102:3 141:7

Dmitrievich,55:13

Dobrolyubova ( 3 )

62:17 62:17 62:18 document ( 73 ) 17:1 22:23 24:9 24:15 28:17 29:14 29:19 29:23 38:12 39:10

39:21 40:1 40:9 42:22 52:21 54:4 54:13 54:17 56:12 56:13 67:21 80:22 85:10 85:11 85:15 85:19 85:19 86:3 86:4 86:16 86:17 86:23 86:25 87:14 87:19 87:19 87:25 87:25 88:1 88:3 88:4 91:23 103:15 109:1 109:5 109:18 109:23 109:24 111:12 111:24 112:2 112:7 112:8 112:18 113:21 113:23 114:14 115:12 116:18 116:24 117:17 118:4 118:8 118:11 119:3 122:16 125:7 125:9 125:19 125:25 126:2 133:10 133:16

documentation. ( 5 )

16:17 29:17 60:11 107:7 131:21

documents ( 100 )

13:13 13:17 13:23 14:11 16:7 16:9 16:12 16:20 16:21 17:16 18:1 18:18 18:19 18:24 20:4 20:22 20:22 21:11 23:9 24:3 26:1 28:12 28:16 28:19 29:7 30:2 30:25 33:4 37:19 37:20 38:6 38:18 39:7 39:8 39:21 40:9 40:11 40:21 41:9 41:10 42:5 44:2 44:6 44:11 49:4 52:17 53:23 54:1 57:13 61:6 61:9 62:15 63:1 63:4 63:17 63:23 85:1 85:8 85:11 85:12 85:21 85:23 86:14 87:23 88:5 88:7 89:18 91:25 92:14 95:2 95:13 95:16 95:18 101:12 101:15 109:14 111:7

112:12 116:10 116:12 117:10 117:15 117:19 117:20 118:2 118:20 120:24 125:8 126:6 131:20 132:12 132:19 132:24 133:3 133:6 133:7 133:15 140:10 176:5 176:8

does ( 35 ) 10:25 18:13 18:14 21:22 21:25 22:13 36:3 43:5 55:22 57:13 57:18 62:13 64:15 68:4 72:21 75:1 84:23 91:3 92:9 93:15 95:6 97:21 123:25 126:19 135:22 142:7 148:14 149:4 155:9 156:17 157:1 157:2 158:1 163:18 167:2

doesn’t ( 19 )3:14 10:2 11:12 32:3 40:16 41:7 55:23 56:12 75:2 77:2 100:17 110:17 122:12 129:1 142:11 145:24 163:17 172:2 177:15

doing ( 12 ) 14:13 19:5 21:13 39:16 70:8 95:20 97:12 115:11 131:19 157:24 164:1 166:3

don’t ( 87 )1:8 3:15 4:25 8:2 8:18 12:14 17:23 19:3 19:5 19:12 22:25 23:11 25:19 32:14 33:4 33:10 36:4 36:17 36:25 40:12 43:2 44:3 54:8 56:23 65:7 68:8 70:6 70:25 71:17 76:6 76:14 76:18 77:9 77:11 84:15 86:18 87:11 88:21 90:4 91:9 91:22 92:3 92:17 92:22 93:1 95:8 100:1 106:21 109:10 110:19 112:21 119:12 123:3 124:14 128:4 130:12 131:23 131:23 132:19 133:24 134:4 135:17 136:11 136:24 142:18 143:6 144:11 148:11 149:21 149:23 150:16 151:20 153:24 154:10 156:21 160:12 160:25 161:21 164:4 168:17 170:21 171:18 171:24 172:10 172:25 175:2 175:4

done ( 40 ) 2:2 3:16 10:6 10:10 12:23 15:13 17:14 18:20 22:18 22:25 26:9 27:18 29:13 32:22 47:17 63:21 67:8 75:3 76:25 77:3 79:22 89:2 98:3 98:3 109:20 111:22 111:23 117:8 121:1 126:22 136:17 140:17 145:3 145:7 154:1 158:12 161:11 162:6 176:24 178:9

door ( 4 ) 83:20 91:1 91:22 158:16

dossier,126:3 dossiers,42:5 double-check,4:12 double-checked142:5 double-checking154:22 doubt ( 4 ) 96:3 97:17

111:23 177:17 doubts,12:16

down ( 28 ) 4:5 23:18 27:8 27:9 46:24 50:19 54:15 56:22 56:23 57:7 72:17 73:14 80:2 105:25 115:8 122:25 130:8 141:1 141:23 155:7 159:8 159:18 161:18 165:7 167:5 168:7 173:16 176:21

dozens13:22

[draft] ( 3 ) 69:17 69:21 88:23

drafted123:21 drag93:10 dragged94:5

draw ( 7 ) 10:21 26:14 103:23 115:15 115:22 117:18 131:20

drawing ( 6 ) 14:11 104:16 106:7 107:4 107:15 118:20

drawing-up135:4 drawn ( 5 ) 104:9

104:18 105:2 105:21 110:16

dreams?98:9 drink94:24 drinking94:25 drinks.95:4 drive?81:19 dropped ( 2 ) 108:7

121:17

due. ( 10 ) 14:1 51:17 51:22 66:25 74:3 113:14 132:1 150:14 154:2 158:24

dull,146:12

duly. ( 2 ) 37:17 111:15 duplicate174:14 duplicated,61:24 duration168:16 duress108:21

during ( 9 ) 35:12 44:14 82:5 95:20 103:1 111:7 120:2 121:12 144:23

duty ( 2 ) 101:1 114:5

E

e-mail ( 35 ) 1:9 1:23 35:3 54:22 55:4 55:4 55:5 55:6 55:7 55:9 55:11 55:23 55:24 56:6 56:7 56:11 56:17 57:14 63:21 105:22 105:23 106:2 106:10 106:16 126:9 136:14 136:16 143:12 143:15 147:11 147:24 148:13 149:3 149:5 178:2

e-mails. ( 6 ) 31:1 31:2 31:6 31:17 36:14 54:19

{E1/2/16}.87:14 earlier ( 8 ) 4:1 15:17

29:5 116:18 133:12 152:7 162:13 176:18

early ( 5 ) 13:6 35:13 53:18 72:25 82:11 earth ( 2 ) 5:6 165:14

easier ( 2 ) 13:19 71:13 easiest155:10 economic ( 4 ) 7:13

11:17 120:2 121:12 editorial?64:6 Edwards,71:1

effect ( 5 ) 29:1 29:25 109:15 124:2 167:16

effective, ( 2 ) 5:6 12:9

effectively ( 2 ) 98:3 168:12

efficient74:9 efforts ( 2 ) 170:2
172:11

either ( 14 ) 33:14 63:22 68:17 92:3 99:19 105:6 105:19 129:10 132:10 139:17 156:13 159:11 167:7 175:15

EKATERINA ( 4 ) 102:4 102:10 119:18 179:20

elaborate ( 2 ) 153:2 154:19

elaborations150:17 elapsed33:3 elastic74:14 electronic20:22 Electrostatic87:24 ELENA ( 3 ) 6:7 71:1
179:4

Elevatornaya111:2 eliminate135:7

else, ( 10 ) 17:21 29:22 37:4 42:18 113:9 124:17 139:15 154:17 172:12 174:14

elsewhere, ( 2 ) 57:25

174:13

Embankment,80:8 emerge? ( 2 ) 62:8
147:24

emerged ( 2 ) 84:17 176:8

emergency.1:8 emphasise47:12 employed96:4 employee, ( 8 ) 15:7
19:8 32:9 33:4 33:7 33:10 119:19 161:10

employees ( 10 ) 18:5 23:22 42:7 109:21 110:6 115:2 115:19 117:16 118:7 131:11

empty ( 3 ) 111:4 153:25 154:10

enable169:17 encapsulated68:5 encash146:24 enclosing154:6 encompass139:8 encompassed ( 2 ) 9:6

64:21 encountered78:24 encourage151:8

end ( 18 ) 12:24 13:25 15:4 31:13 54:16 59:13 66:14 73:3 73:18 98:4 104:8 106:20 108:15 108:17 159:7 164:14 168:9 172:24

endeavour ( 2 ) 15:21 137:7

endeavoured ( 2 ) 33:19 93:5

endlessly ( 2 ) 164:17 165:6

endurance178:10 enduring178:9 enforce ( 7 ) 7:20 7:25

9:11 10:3 10:19 11:5 122:4

enforced9:1 enforcement ( 3 ) 7:21

7:22 11:5 enforcements9:7 enforcing9:2 engaging108:1 English ( 26 ) 21:18
39:9 52:20 53:13

55:1 56:24 57:9 87:13 107:20 115:6 115:8 116:16 117:2 118:25 122:25 134:12 167:12 167:13 167:14 167:15 167:17 168:2 170:3 170:4 170:11 170:12

enough ( 10 ) 45:4 66:5 74:7 76:9 95:15 108:6 112:13 123:12 132:15 163:22

ensure74:9 entails.145:1

enter ( 3 ) 15:14 40:13 51:25

entered ( 10 ) 17:12 20:12 28:8 29:8 39:25 41:21 55:17 83:9 90:16 108:19

Entering ( 5 ) 40:5 41:1 49:20 90:14 128:12 entire ( 3 ) 26:19 27:1
85:17

entirely ( 4 ) 113:1 126:17 145:14 163:9

entirety ( 3 ) 18:9 27:3 63:22

entities137:10 entitled ( 2 ) 7:25

159:20 entitlement165:3 entries, ( 2 ) 140:14

141:7

entry ( 9 ) 15:14 44:8 47:5 47:9 48:9 48:15 49:2 49:8 123:6

envelope62:22 envisaged, ( 2 ) 162:17

162:19 equipment87:22 equivocation60:9 erased,21:22

error ( 7 ) 2:3 3:9 29:13 63:8 63:10 63:12 69:20

errors, ( 2 ) 63:2 64:3 escorted91:5 esoteric.71:4 especially13:12 essentially ( 5 ) 1:13

7:13 13:6 85:23 162:9 establish, ( 2 ) 46:20

86:22

estate ( 11 ) 7:16 51:13 114:6 114:9 114:12 115:4 115:16 116:3 117:20 118:15 121:17

estimate ( 7 ) 97:11 97:22 100:14 159:7 159:15 163:15 169:15

estimated115:15 estimates ( 2 ) 97:11

158:8 euros4:3 evaluate137:9 evaluating.58:19

even ( 22 ) 11:11 19:17 22:12 22:16 31:3 41:3 44:13 47:15 59:19 72:25 86:12 97:22 108:18 133:20 136:25 147:3 150:17 156:25 159:7 159:14 161:2 170:5

evening6:5

event ( 10 ) 47:19 94:15 103:21 105:17 106:15 114:23 137:11 138:20 170:4 170:14

events ( 7 ) 11:13 13:5 30:7 62:2 84:16 92:12 94:20

ever ( 13 ) 28:13 28:22 29:2 29:6 29:7 29:25 35:7 42:24 105:8 105:9 132:7 135:25 169:21

every ( 22 ) 23:24 25:8 28:6 33:12 60:9 61:10 61:12 86:6 87:4 118:11 125:8 127:19 127:20 127:22 128:4 128:10 128:12 128:14 128:17 161:21 162:12 171:6

everybody ( 2 ) 167:20 171:25

everybody’s22:19 everyone ( 3 ) 21:15

98:1 143:15 everything ( 8 ) 16:11

63:12 103:5 111:22 153:25 164:23 167:13 168:24

evidence ( 34 ) 5:6 6:15 8:19 14:18 22:15 25:1 26:10 31:9 31:20 44:16 44:21 44:25 45:19 48:13 59:25 70:16 73:3 81:12 82:8 86:23 89:25 93:2 93:5 93:12 96:9 96:13 104:20 127:13 131:14 136:7 140:21 142:9 158:24 161:19

exact ( 10 ) 35:15 36:21 69:10 81:11 87:7 94:19 99:8 110:4 131:1 168:17

exactly, ( 30 ) 19:22 19:24 24:19 31:17 32:24 33:6 36:8 36:20 43:2 46:8 48:17 55:10 57:17 59:4 59:16 62:2 64:7 68:12 70:6 75:22 81:20 81:25 82:7 82:15 85:4 85:20 91:21 92:5 129:23 130:16

exaggerated. ( 2 ) 120:1 121:5

examination ( 3 )

100:25 119:24 120:20

Examination-in-chief ( 4 ) 80:4 102:7 179:14 179:22

examined ( 3 ) 25:21 87:23 88:2

example, ( 13 ) 7:9 58:2 59:14 61:21 63:14 63:24 114:23 114:25 133:25 134:15 135:5 138:11 145:4

examples ( 2 ) 131:24

133:12 exceeding137:12 exceeds10:17 except ( 6 ) 6:8 79:25

96:9 102:5 121:15 137:15

exceptionally100:7 exceptions,7:12 excerpts66:9 executed ( 3 ) 23:10

28:16 52:2 executing39:25 executive ( 3 ) 50:16

66:10 66:21 exhaust122:11 exhausted.143:10

exhausting162:13 exhaustive24:22 exhaustively25:21 exhibit, ( 6 ) 44:2 47:10
53:24 53:25 54:15 122:17

exhibited ( 10 ) 46:17 46:20 47:5 49:10 53:21 54:1 54:14 54:18 54:25 56:8

exhibits46:17

exist, ( 2 ) 62:13 139:16 existence, ( 2 ) 47:24
129:8

existing ( 3 ) 20:18 145:20 156:10

expect ( 10 ) 9:16 10:2 10:18 38:23 43:20 45:10 51:24 52:2 87:2 153:25

expectation ( 2 ) 149:16 165:6

expected ( 2 ) 5:15 44:1 expenses, ( 5 ) 4:4

144:20 148:8 148:8 153:11

expensive108:4 experience ( 4 ) 12:12

51:24 94:4 114:11 expert ( 3 ) 87:16

110:22 176:12 experts ( 4 ) 30:13

69:12 86:21 162:5 explain, ( 14 ) 15:18

52:22 52:23 63:1 63:25 86:20 94:10 95:19 107:25 109:22 127:10 150:4 150:6 152:21

explained ( 5 ) 5:2 31:20 119:22 120:19 137:2

explaining ( 2 ) 99:19 127:11

explanation ( 4 ) 5:17 24:22 78:7 87:10

explanations. ( 2 ) 42:7 99:8

exploit111:10 explored ( 2 ) 26:13
148:4

express ( 2 ) 113:17 150:14

expressed ( 3 ) 147:21 149:12 162:23

expression123:15 expressly: ( 2 ) 126:10

156:1 extend138:18 extended. ( 7 ) 23:21

28:7 28:10 51:6 110:1 123:17 123:17

extending ( 3 ) 7:9 10:12 121:8

«Extension50:20 extent ( 3 ) 27:6 104:5

128:14 extra93:7

extract ( 5 ) 50:8 54:17 55:22 87:15 118:24

extracted54:25 extraordinary125:22 extravagant,26:21 extreme2:22 extremely ( 2 ) 26:22

108:4

eye ( 3 ) 87:22 89:14 129:2

F

fabricated ( 2 ) 27:25 28:19

face144:14 face-to-face ( 2 ) 31:5

125:2 factors114:24 fail45:2 failed64:12

fair, ( 9 ) 78:14 100:5 116:13 129:23 129:25 161:20 165:5 165:10 168:19

fairly ( 3 ) 25:21 134:7 161:9

fairness ( 5 ) 52:16 67:18 159:20 165:4 172:18

fall ( 4 ) 17:9 18:22 148:2 173:13

fallen ( 2 ) 17:6 31:16 falls42:9

false ( 6 ) 24:25 25:9 25:9 25:10 68:1 68:1

family ( 2 ) 44:20 153:8 fantastic70:8

far ( 40 ) 3:16 7:19 10:6 11:3 15:5 16:5 17:17 18:12 18:18 21:21 36:18 38:24 42:2 56:19 60:23 61:12 61:23 62:11 63:7 63:16 67:10 81:16 81:21 84:3 85:16 90:2 95:1 105:4 107:5 117:3 123:4 126:4 126:8 131:21 139:23 141:6 156:21 163:9 169:16 178:9

fast146:25

fault. ( 6 ) 46:19 46:19 53:16 113:1 126:17 160:14

favour74:18 favourable115:13 faxes,31:2

fear. ( 2 ) 136:8 136:9 featured133:4 February ( 4 ) 1:1 159:3
159:4 178:15

Federation, ( 6 ) 18:15 138:8 138:25 139:21 140:21 142:14

feed ( 16 ) 166:13 166:21 167:2 167:4 167:8 167:23 168:12 168:25 169:2 169:6 169:24 170:9 170:24 170:24 173:19 174:15

feel ( 7 ) 15:17 19:3 19:5 22:25 23:11 68:9 147:7

feeling149:15 fees,108:8

fell ( 4 ) 30:15 120:2 121:12 124:11

few ( 6 ) 62:10 62:20 91:20 126:5 129:7 148:24

fiction.93:4 fifth100:8 fight163:7

figure, ( 2 ) 137:12 168:17

figures, ( 2 ) 59:4

116:20

file ( 13 ) 29:3 43:17 44:18 49:1 85:2 85:17

86:15 102:15 118:21 125:9 126:3 132:19 156:9

filed47:25

files ( 6 ) 18:8 42:4 125:17 125:19 142:6 156:10

filled66:13

final ( 2 ) 14:3 17:22 finance ( 3 ) 23:23 108:9 144:19 financial ( 12 ) 11:23
12:20 37:23 39:17 40:2 40:24 51:17 51:22 70:1 110:3 123:19 137:13

find ( 12 ) 13:3 22:3 45:14 50:11 74:18 80:20 93:14 102:15 125:9 126:8 127:25 162:4

finding ( 2 ) 75:13 90:22 findings88:9 fine174:16 fingertips,151:8

finish ( 10 ) 1:18 38:22 73:18 75:14 76:15 76:17 97:23 100:5 100:24 134:7

finished, ( 6 ) 31:25 38:23 77:3 100:13 118:19 159:6

firms107:17

first ( 47 ) 5:1 14:25 15:2 15:13 15:19 15:19 16:3 32:5 38:13 44:7 48:23 49:10 50:9 50:16 52:19 52:25 62:10 65:3 66:6 66:8 66:22 70:12 72:12 73:9 74:15 74:23 75:1 78:4 79:7 84:18 87:20 90:13 90:25 110:20 117:11 119:4 137:3 146:1 155:22 158:5 159:18 163:2 163:6 165:24 166:2 175:12 175:18

firstly,23:12

five ( 10 ) 9:8 59:2 96:5 135:19 135:20 143:11 143:24 145:7 148:23 171:7

five-day100:9 fix168:6

fixed ( 2 ) 72:22 163:4 flag, ( 3 ) 79:3 140:13

156:16 flagged140:12 flagging97:21 flatly3:24 flee,169:13 flexibility164:10

flexible ( 7 ) 74:14 77:1 157:21 157:21 163:10 164:17 173:8

floor, ( 4 ) 90:23 90:23 90:24 90:25

flown158:20 fly73:8

focus ( 3 ) 15:16 89:19 161:7

focused148:1 follow ( 4 ) 55:3 56:2

165:17 174:24 followed ( 2 ) 101:21
131:16

following ( 5 ) 14:24 32:1 51:5 73:23 111:7

follows ( 5 ) 8:23 51:2 53:14 64:19 72:10

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footing;150:20
173:9 174:5 179:10
grant ( 2 ) 127:5 127:7
half ( 8 ) 72:19 77:3 79:7

forbid,7:15
179:17
granted15:9
97:11 98:17 163:16

force141:5
future. ( 3 ) 3:6 156:14
grateful, ( 6 ) 8:11 30:4
164:14 166:25

forced67:25
157:4
68:11 71:18 113:16
halfway141:23

forcefully128:7
166:15
hand ( 2 ) 98:25 101:11

Ford89:19
G great ( 2 ) 164:6 170:2
handed ( 3 ) 132:12

forensic ( 3 ) 86:21
greater?58:18
140:21 165:11

86:23 87:15
green ( 2 ) 89:19 92:8
handle99:18

gallop177:23

forgot, ( 2 ) 95:9 95:12
grey95:8
handled155:15

form, ( 10 ) 20:2 105:20
gather ( 2 ) 34:25
Grigory ( 2 ) 119:5
hands. ( 5 ) 95:18 146:3

123:17 126:22 128:23
163:16
119:6
146:6 146:11 160:3

131:8 131:10 131:12
Gavani111:2
ground ( 2 ) 100:18
handwriting ( 3 ) 86:21

142:5 142:15
gave ( 5 ) 35:7 43:17
101:5
87:16 87:18

formal ( 3 ) 40:13 40:16
72:4 119:14 152:11
group ( 10 ) 15:8 31:10
hang145:10

131:22
general ( 10 ) 7:12 36:2
59:19 81:10 82:6 88:7
happened, ( 26 ) 5:18

formalise15:14
57:1 67:18 111:16
88:10 108:7 137:16
14:25 15:4 16:7 27:6

formalising15:3
118:6 126:1 133:2
137:19
47:13 47:19 48:17

formalities139:3
134:4 137:11
Group’s108:1
49:4 49:7 57:14 63:4

formally2:16
generally ( 2 ) 83:5 83:6
groups137:8
77:24 78:17 86:18

formed58:21
gentleman167:24
grow.116:23
94:11 125:22 128:5

forms,93:25
genuine148:7
growing ( 2 ) 59:5 59:5
129:6 134:24 135:2

formula6:25
gesture35:18
guarantee ( 69 ) 6:19
135:4 135:9 146:17

formulated ( 4 ) 41:6
get ( 23 ) 4:6 4:8 4:18
7:10 8:1 8:10 9:3 9:7
169:20 177:10

46:8 68:12 76:14
4:23 5:12 5:15 12:5
9:8 9:12 10:19 10:22
happening ( 3 ) 36:24

formulating11:15
15:17 34:24 76:22
11:22 12:1 12:8 12:13
123:24 170:4

forth,40:3
78:4 79:21 81:18
12:19 12:21 19:17
happens ( 2 ) 124:13

forward,142:11
96:20 97:17 140:17
19:20 20:11 20:11
168:11

found ( 8 ) 31:9 80:11
141:13 144:5 146:8
28:23 29:3 29:11
happier152:16

88:3 88:5 88:12 106:6
155:19 155:23 158:22
37:8 37:10 39:25 40:6
happy ( 11 ) 19:4 21:15

131:4 173:25
162:2
40:12 40:13 40:17
103:24 105:20 124:2

foundations,165:23
gets149:10
41:1 41:11 41:12
124:9 127:7 127:17

fountain94:25
getting ( 6 ) 32:3 34:22
41:20 41:21 45:20
162:15 163:14 174:2

four ( 8 ) 35:1 62:21
49:21 49:24 98:1
49:22 49:25 51:17
hard ( 7 ) 22:2 22:5

125:20 153:17 158:9
145:23
51:22 52:1 52:2 55:17
66:17 102:14 108:11

159:16 160:21 161:22
gist22:20
57:16 61:20 64:16
164:5 176:4

four-day73:20
give ( 39 ) 9:17 9:19
65:1 67:16 70:5 70:10
hard-working108:6

fourth ( 5 ) 64:10 64:15
12:8 12:13 13:19 29:4
70:18 122:23 123:2
hardly21:25

64:21 65:2 100:8
31:8 32:11 48:13 74:3
123:3 123:13 123:23
hardwired168:8

frame, ( 2 ) 19:24
74:7 74:21 74:24 77:7
124:3 124:20 126:12
harm ( 2 ) 23:12 26:9

103:24
77:18 80:5 85:17 93:2
126:20 126:21 128:13
harsh, ( 2 ) 163:24

framed,25:7
96:12 101:20 102:8
130:21 130:25 137:15
164:3

framework43:12
119:6 124:22 134:15
138:9 138:14 138:18
hasn’t ( 3 )19:18 45:22

France ( 5 ) 2:12 3:4
135:8 136:13 139:24
138:21
141:12

53:8 78:24 153:6
150:6 152:8 152:24
guarantees. ( 32 ) 6:14 haven’t ( 10 )23:4

frankly,162:10
153:13 156:16 158:24
6:17 7:6 9:6 12:6
24:10 24:17 45:5 67:7

frantic19:16
161:20 169:5 171:5
12:8 20:6 27:21 27:25
81:13 99:20 126:12

free, ( 4 ) 32:8 40:25
171:15 173:5 173:9
28:5 32:17 37:5 37:22
142:5 148:21

97:2 99:16
given, ( 22 ) 8:24 26:1
38:5 38:7 39:16 39:23
hazy132:17

freezing ( 13 ) 145:1
27:22 28:24 29:21
39:24 42:1 52:7 60:8
head ( 3 ) 17:19 129:14

145:11 145:17 145:20
34:6 34:7 37:4 37:6
60:10 60:13 61:1 61:7
129:17

146:24 147:17 148:3
37:7 44:21 51:10 60:2
66:23 67:12 67:13
headphones, ( 2 ) 70:16

148:6 152:13 152:14
80:16 85:21 90:15
67:13 123:9 127:12
167:8

153:11 154:6 156:25
96:18 97:12 122:20
128:25
hear ( 10 ) 150:16

French ( 8 ) 3:14 5:6
138:9 158:5 177:21
guarantor. ( 17 ) 11:2
157:24 158:17 166:2

53:10 99:7 99:18
gives ( 3 ) 79:12 140:20
11:23 31:15 32:20
167:10 167:16 167:17

143:20 145:9 155:20
161:3
37:24 37:25 40:21
173:22 173:23 174:7

frequency,110:4
giving ( 6 ) 7:14 44:25
40:25 41:22 51:23
heard ( 3 ) 74:24 166:4

Friday ( 8 ) 73:21 77:7
85:25 86:15 96:9
61:16 64:14 65:7
169:14

160:4 160:6 161:4
116:19
65:14 65:17 137:3
hearing ( 3 ) 146:22

161:5 162:16 163:13
glance.70:12
137:21
146:23 175:8

friends ( 2 ) 75:6 125:13
glass,42:10
guarantors ( 8 ) 11:10
heaven5:5

frightened ( 3 ) 43:9
global ( 2 ) 120:2
32:23 33:2 34:5 39:18 heavy ( 2 ) 108:7 162:18

43:11 136:4
121:12
55:20 57:4 65:6
held95:18

front ( 3 ) 22:5 102:15
gloomy,98:12
guidance,131:25
help ( 5 ) 18:16 22:3

140:23
God7:15
guided138:16
78:10 99:24 151:20

frozen,3:3
gone ( 5 ) 10:16 36:20
guidelines ( 2 ) 41:5
helped45:14

FTI177:8
90:10 112:8 138:3
58:11
helpful, ( 7 ) 50:11

full ( 7 ) 10:11 55:23
good ( 25 ) 1:4 5:23 6:5
guru172:5
50:12 54:10 71:16

59:14 80:6 102:9
6:11 21:23 22:6 22:14
Guz, ( 14 ) 73:8 73:12
113:22 174:25 175:7

118:20 158:6
22:19 55:13 71:10
75:25 158:13 158:15
helpfully,85:1

fully159:20
78:22 81:9 83:8 96:13
158:18 159:1 159:5
here ( 28 ) 11:13 12:18

function12:5
103:10 117:1 123:12
159:6 159:12 159:25
14:7 21:11 40:10

fund169:10
133:25 135:20 150:9
160:18 161:8 163:12
40:15 43:20 46:14

funds154:7
154:19 156:2 170:17
Générale. ( 2 ) 99:9
48:15 55:6 57:24 64:2

further ( 25 ) 2:4 4:24
172:6 175:1
145:10
69:24 72:13 76:21

8:12 27:24 42:18
goods7:3
94:12 96:3 97:10

50:24 68:22 69:16
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H 97:16 105:22 128:18

71:7 95:6 95:11 95:23
165:14
151:10 151:19 156:18

114:16 130:13 142:4
government ( 2 ) 43:1
160:10 160:11 160:14

habit86:19

145:15 161:18 166:12
43:4
170:5

171:21 172:11 173:6
graduated,59:1
hadn’t122:2
hereto48:15

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herself,103:22 HGV,82:3

hide ( 3 ) 47:8 48:9 48:12

high, ( 4 ) 106:7 106:8 106:17 172:16

higher ( 2 ) 58:25 116:8 highly ( 2 ) 9:3 10:18

HILDYARD: ( 282 )

1:4 1:11 1:15 1:21 2:8 2:16 3:1 3:7 4:8 5:11 6:3 8:2 8:14 8:21 12:23 13:1 13:4 15:12 15:16 16:2 21:7 21:13 25:3 25:7 25:18 26:15 26:18 26:25 27:13 28:22 29:2 29:10 29:21 30:3 30:6 38:17 38:19 38:25 45:21 46:1 46:5 46:13 46:15 48:20 48:22 49:9 49:17 50:13 57:20 57:21 58:14 59:7 59:13 59:23 60:7 60:23 61:5 61:12 62:4 62:24 64:6 64:8 64:23 65:9 65:13 65:18 65:21 65:24 66:4 66:11 66:20 67:2 67:6 67:10 67:17 68:3 68:19 69:14 70:5 70:24 71:3 71:9 71:22 72:1 72:6 72:15 74:20 75:1 75:9 75:16 75:19 76:3 76:10 76:18 76:21 77:2 77:13 77:18 77:21 78:2 78:14 78:20 79:2 79:9 79:12 79:15 79:23 80:2 89:2 89:4 93:17 93:19 93:20 94:3 94:13 94:21 95:5 95:10 95:23 96:1 96:2 96:7 96:12 96:17 96:19 96:22 96:25 97:8 97:16 98:5 98:9 98:12 98:21 99:12 100:11 100:21 101:15 101:19 101:22 101:25 105:3 109:14 112:18 112:24 113:4 113:10 128:1 130:4 132:6 132:16 132:22 133:7 133:24 134:9 134:11 135:15 135:20 136:12 136:15 136:19 136:21 136:22 137:20 137:25 138:4 138:23 139:2 139:12 139:19 139:23 140:5 140:11 140:15 140:19 140:25 141:4 141:10 141:14 141:16 141:21 142:1 142:8 142:11 142:18 142:22 143:1 143:3 143:9 143:15 143:18 143:22 143:24 146:12 146:16 146:20 147:1 147:11 148:25 150:8 151:2 151:14 152:2 152:8 152:10 152:16 152:18 152:23 152:25 153:4 154:12 155:8 155:24 156:21 157:10 158:2 158:14 158:16 158:22 158:25 159:3 160:7 160:12 160:16 160:20 161:6 161:11 161:24 162:7 162:12 162:22 163:5 163:21 163:24 164:3 164:5 164:23

165:9 165:13 165:15 165:20 166:1 166:5 166:10 166:17 167:2 168:1 168:22 169:12 170:12 170:15 171:2 171:8 171:11 171:16 171:21 172:5 172:15 173:4 173:7 173:12 173:22 174:9 174:18 174:21 175:1 175:3 175:7 175:14 175:20 175:25 176:11 176:17 176:23 177:3 177:13 177:21 178:6 178:12 179:9 179:16 179:18 179:24

himself; ( 7 ) 57:11 103:22 103:24 106:21 119:8 119:12 119:13

hints108:8 hire166:23 history104:6

Hold ( 2 ) 130:4 136:12 holiday.14:15

home. ( 3 ) 97:3 132:9 135:20

hones172:2

honest, ( 5 ) 21:25 38:9 43:22 59:16 68:14

hoof.150:17

hope ( 21 ) 1:6 1:22 6:5 6:5 9:21 9:25 68:5 68:17 71:10 72:9 73:17 74:18 76:9 76:15 76:17 80:2 96:20 101:13 126:5 164:19 164:21

hopefully, ( 3 ) 73:21 151:19 163:15

hopes8:24

hoping ( 2 ) 2:10 140:16 hopping56:5 horrendous177:15 horribly,149:17

hour ( 10 ) 2:12 4:14 76:16 79:5 82:25 98:2 98:11 144:4 164:14 166:25

hours.73:19

house ( 2 ) 111:3 111:3

Housekeeping ( 18 )

1:3 72:2 72:25 97:5 97:7 97:24 97:25 98:2 100:8 112:11 140:1 144:3 146:9 177:11 179:3 179:11 179:19 179:25

hoving149:25 however, ( 8 ) 6:23 7:24

10:9 34:4 58:24 61:10 63:20 108:2

huge83:5

human ( 2 ) 131:18 164:6

hurry, ( 2 ) 29:11 63:2 hut?83:6 hybrid168:4

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I’m ( 61 )1:5 6:4 9:13 9:14 9:15 9:18 11:7 19:21 22:22 23:1 24:20 26:11 26:14 28:8 28:15 30:4 38:24 41:6 46:3 46:8 48:22 55:10 57:21 57:23 66:16 68:11 68:14 79:4 81:11 82:15 83:17 84:23 94:12

132:15 134:7 145:21
longer ( 4 ) 58:24 81:25
Luncheon79:17

167:5 168:7 168:8
82:25 135:18
lunchtime, ( 2 ) 97:13

173:2
look ( 40 ) 1:9 10:23
159:14

line-up74:6
21:11 21:25 22:13
luxury90:8

lines ( 4 ) 44:6 69:21
37:8 37:9 38:12 40:19

69:22 106:9
40:24 50:19 56:5 56:6
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link ( 3 ) 137:18 161:17
56:10 57:13 59:12

168:10
75:1 84:21 84:23

{M1/20/30}. ( 2 ) 52:19

list ( 5 ) 16:14 107:8
110:9 116:11 116:15

107:12 161:12 178:2
116:25 117:10 122:16
53:12

listed177:13
122:22 129:23 130:12
{M1/20/69}53:2

listen ( 4 ) 70:22 125:14
136:22 137:4 145:24
machine112:14

168:2 170:10
149:20 152:3 162:5
Madame148:15

listener171:3
162:5 165:22 165:24
magnifying42:10

listening ( 3 ) 70:16
166:6 172:10 173:19
Magnum, ( 9 ) 54:3

167:12 168:14
looked ( 12 ) 14:2 16:12
66:18 140:16 141:14

literally ( 3 ) 3:3 13:22
29:18 37:19 38:12
165:16 173:17 173:18

152:25
39:10 39:13 42:4
173:20 174:11

little ( 8 ) 8:12 13:2
85:23 90:18 120:24
mail ( 11 ) 30:11 31:1

31:17 37:1 42:21
158:3
31:22 32:2 32:6 34:3

42:23 100:7 176:24
looking ( 18 ) 13:18
34:9 35:19 60:12

live ( 4 ) 80:7 153:24
22:23 34:19 42:10
60:13 61:8

154:11 166:21
45:12 73:6 86:4 95:2
main ( 3 ) 41:17 41:19

lives,25:24
109:11 110:18 113:12
123:23

living ( 3 ) 148:7 153:7
113:13 123:19 126:7
major ( 4 ) 18:25 42:9

153:11
130:6 134:5 158:6
66:9 135:5

load158:7
172:1
makes70:18

loan ( 82 ) 6:16 6:22
looks ( 16 ) 28:11 51:15
making ( 9 ) 20:14 24:1

6:25 7:9 7:10 7:14
56:7 56:11 57:2 57:17
38:2 45:24 46:11 61:6

8:24 8:25 9:17 9:21
70:12 80:15 100:5
96:3 116:21 169:15

9:23 9:24 9:24 9:25
100:9 102:18 116:5
man, ( 5 ) 83:25 84:21

10:5 10:12 10:17
123:22 131:15 136:7
84:22 84:23 100:1

13:14 19:18 20:13
161:23
management, ( 7 )
20:14 20:16 23:20
loose86:15
14:14 41:18 50:4 50:8

24:2 28:6 28:7 28:10
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51:24 124:5 154:2

28:10 28:11 28:12
Lordship. ( 86 ) 1:5 manager, ( 2 ) 16:15

28:14 29:17 30:15
3:20 4:1 4:24 5:9
61:18

35:15 37:22 37:23
28:9 38:22 39:5 48:10
managers,36:14

39:11 39:15 39:15
50:11 55:3 55:9 55:11
mandated59:7

41:20 50:10 52:1
57:18 65:6 65:8 65:10
manner). ( 2 ) 88:2

55:14 64:10 64:16
65:11 65:25 66:1 66:2
103:23

64:21 65:2 66:6 87:2
66:5 66:12 66:14
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88:12 103:25 105:14
66:18 66:22 67:5
34:13 39:21 40:3 40:9

107:6 108:18 108:23
67:14 68:25 69:22
45:18 66:13 76:18

109:25 110:8 111:6
70:2 71:7 74:8 74:19
85:7 94:20 121:18

116:21 118:1 118:21
75:5 75:7 79:19 80:5
Maps,165:14

122:20 123:6 123:14
81:1 84:6 88:19 89:8
March ( 9 ) 35:6 35:13

123:16 125:9 125:12
93:15 95:20 97:22
36:6 36:10 36:24

125:17 125:20 126:1
99:5 99:20 100:6
50:10 50:17 55:15

126:3 126:3 126:19
102:8 103:2 109:11
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127:2 127:21 128:17
112:11 113:15 114:2
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131:10 131:19 131:21
134:10 140:2 140:3
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137:4 137:16 137:24
140:6 140:14 140:17
31:10 81:10 82:6 91:3

loans? ( 36 ) 9:19 16:1
140:23 141:2 142:7
marked1:9
20:12 30:9 31:16
143:6 144:12 144:15
market. ( 10 ) 114:12

42:10 49:20 50:5
145:22 146:1 150:4
114:18 114:24 114:25

50:20 51:6 53:18
152:11 152:19 156:17
115:19 116:3 116:9

61:1 65:22 66:7 93:24
158:1 158:3 158:18
117:7 117:21 121:9

93:24 93:25 94:1
159:22 160:9 165:19
married ( 2 ) 138:15

94:1 94:1 94:2 104:10
165:22 165:23 166:15
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104:18 104:21 104:23
166:21 167:11 170:7
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105:2 110:1 119:20
173:24 178:3
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119:23 120:5 120:19
Lordship’s ( 15 )21:12
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121:8 121:21 122:4
67:4 68:18 72:5 72:23
material ( 3 ) 19:13

125:19 128:25
73:4 79:21 140:8
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local ( 2 ) 154:3 155:15
146:3 146:6 146:11
maternity32:5

located? ( 3 ) 83:3
160:3 160:24 165:11
matter ( 30 ) 1:7 1:19
89:10 111:1
173:14
2:8 4:13 8:12 17:24

location. ( 2 ) 81:11
lose ( 2 ) 74:10 99:4
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115:13
losses.7:17
78:6 78:22 84:7 92:20

logical.16:18
lost ( 3 ) 38:18 120:4
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logistically71:13
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logistics166:22
lot ( 14 ) 3:3 11:8 13:8
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logo ( 2 ) 89:20 91:2
13:13 20:4 25:11
148:8 148:17 150:22

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133:10 168:6 170:4
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matters, ( 7 ) 33:20

19:3 19:4 20:25 81:17
lowered137:23
42:25 77:5 79:22

81:19 98:4 98:5 98:12
LPK ( 2 ) 137:2 137:14
92:24 101:2 132:4

98:14 100:17 100:18
lunch ( 5 ) 82:9 82:13
maturities124:8

135:17 143:11 163:21
82:14 82:15 82:19

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maybe, ( 14 ) 21:10 26:12 32:10 43:1 48:16 72:25 78:2 91:15 95:17 100:6 158:4 175:16 177:16 177:24

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mode139:13

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morning’s144:21 morrow,177:15 Morskaya80:8 mortgage ( 2 ) 10:9
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observations ( 2 ) 72:5
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obtain ( 2 ) 94:5 105:15
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obtained,115:23
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obtaining39:24
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obvious ( 2 ) 26:25
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112:5
options, ( 2 ) 167:22
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167:25
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75:21 77:4 78:1 83:20

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85:10 87:9 91:14 98:2 110:19 113:19 117:1 132:25 157:18 171:11 177:13

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persons ( 2 ) 138:17 139:10

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pledges ( 4 ) 7:5 11:9 118:9 121:1

plenty ( 2 ) 161:1 161:2

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14:10 20:4 73:6 75:24
125:18 126:6 133:4
provisions ( 2 ) 11:4
133:2 133:3 133:10

79:1 79:13 99:17
144:16 174:7
59:11
134:4 143:9 145:21

99:25 105:10
proceeds148:2
psychological ( 3 ) 145:24 146:25 148:14

prepared ( 13 ) 12:8
process. ( 8 ) 23:19
12:19 69:25 71:4
168:5 170:4 170:21

13:22 16:7 24:8 30:15
32:14 60:1 60:14
publicly.136:18
172:8 174:23

34:22 58:4 63:2 75:20
108:23 122:7 125:12
punishing146:12
quotation53:24

77:14 117:13 120:14
153:12
purchase ( 2 ) 94:2

128:18
processed ( 3 ) 24:3
111:9
R
preparing, ( 9 ) 16:13
104:1 133:15
purport ( 2 ) 34:8

17:16 20:3 31:8 48:13
processes,122:12
133:14

Radley145:4

77:7 82:8 107:6
produce ( 3 ) 118:7
purporting133:7

157:11
118:10 178:1
purpose ( 7 ) 6:19 6:20
railway165:22

prescribe ( 3 ) 139:3
produced. ( 2 ) 108:17
7:12 7:17 8:15 16:19
raise ( 8 ) 71:19 147:1

139:5 139:12
155:6
130:22
156:17 172:17 176:15

prescribed139:16
professional149:13
purposes, ( 2 ) 129:15
176:21 177:10 178:4

prescriptive,74:16
proffered114:13
156:24
raised. ( 7 ) 1:19 98:20

presence ( 9 ) 18:6 26:5
progress177:16
pursuant147:17
146:14 156:1 170:8

87:4 94:8 110:25
progressing.3:12
putting ( 8 ) 11:2 24:14
174:5 177:20

120:25 131:8 131:10
project ( 6 ) 103:23
24:25 25:8 38:14 86:6
raises12:16

178:7
104:16 105:18 106:22
128:21 154:15
rarely87:21

present ( 3 ) 136:2
106:23 108:9
rate,123:10

141:14 163:15
projects ( 3 ) 103:21
Q rather ( 27 ) 12:6 15:3

presented? ( 2 ) 29:15
104:9 104:18
26:12 34:14 41:3

157:9
Prokhor.111:18
58:14 66:12 86:16

qualification108:14

presently ( 3 ) 142:12
promised171:14
91:1 91:2 95:15 98:2

149:4 170:17
prompted ( 2 ) 155:9
quality169:6
98:11 100:19 104:3

preserve176:20
156:8
quarter’s4:14
112:5 115:19 129:13

preserved ( 2 ) 31:18
proof ( 3 ) 34:1 34:6
quarterly ( 2 ) 110:2
132:9 140:18 146:12

31:18
34:8
110:4
162:24 167:6 167:19

press164:4
proper ( 2 ) 10:9 78:11
query ( 2 ) 140:9 173:14
170:1 170:19 176:20

pressed ( 3 ) 34:7 98:22
properly ( 9 ) 23:10 32:4
question ( 44 ) 9:10
Re-examination ( 4 )
144:23
37:16 94:8 103:22
15:13 15:16 15:19
45:7 68:17 68:20

pressing ( 2 ) 120:5
111:20 111:22 111:23
18:11 19:21 20:1 21:6
179:8

121:22
156:23
22:9 24:21 25:7 25:13
re-examining,112:4

pressure ( 5 ) 24:7 25:1
property ( 11 ) 7:3
35:10 38:9 44:19
re-execute29:19

27:16 164:12 177:15
7:4 7:16 11:1 110:6
45:21 46:7 46:9 48:7
re-executed48:6

pressures169:8
110:14 111:4 111:13
50:20 52:11 62:25
re-read103:1

presumably, ( 4 ) 33:7
116:14 117:23 118:13
67:17 68:8 76:5 86:21 re-sent ( 2 ) 61:10 62:18

94:3 105:15 174:19
proportionate164:8
88:20 95:7 95:9 95:19
re-sign ( 2 ) 63:18 63:24

pretend163:3
proposal ( 7 ) 4:9 38:4
95:21 95:23 96:11
re-signature63:9

pretty ( 5 ) 25:10 25:15
39:11 39:23 41:7 41:8
117:13 118:6 126:15
re-signing63:17

157:21 170:17 177:17
74:24
132:11 132:23 133:15
reached ( 3 ) 12:24

14:12 118:23

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reaction173:1

read ( 33 ) 21:8 21:9 21:25 53:12 53:20 60:9 70:10 70:13 80:23 87:9 87:12 95:13 95:16 95:17 101:17 102:24 107:20 110:19 115:12 116:22 118:24 119:15 120:16 120:17 123:4 126:8 130:13 134:18 134:19 136:20 152:18 156:11 169:13

reading,126:5

reads ( 2 ) 51:2 53:16 ready140:18

real ( 14 ) 7:16 51:13 114:6 114:9 114:12 115:3 115:16 116:3 117:20 118:14 121:17 155:22 168:1 170:8

realisation62:6 realise62:8

realised, ( 2 ) 11:2 62:9 realising11:9

reality, ( 4 ) 12:7 17:25 47:18 47:22

reason ( 14 ) 1:23 2:1 2:18 3:10 16:23 17:3 23:2 69:11 106:19 111:19 111:23 113:5 137:2 149:23

reasonable, ( 2 ) 162:25 171:1

reasonableness170:16 reasons ( 9 ) 12:14

23:12 25:5 111:21 112:5 122:3 122:4 137:25 149:21

reassess114:5 rebut131:24 recalculation ( 2 )

110:11 110:12 recall ( 112 ) 12:12

16:11 17:17 20:20 23:17 28:14 32:24 32:25 34:12 34:16 35:15 36:4 36:8 36:8 36:10 36:18 36:20 36:21 36:23 36:25 37:11 38:13 39:13 41:23 42:2 42:14 42:15 42:17 42:24 43:1 43:2 43:3 43:18 44:3 46:8 47:16 48:17 50:2 59:16 61:9 61:14 61:23 62:2 62:3 62:11 63:16 65:19 65:23 67:10 67:14 81:16 81:20 81:25 82:3 82:5 82:7 82:10 82:16 83:4 83:9 83:13 83:19 83:20 83:24 84:7 84:12 84:13 84:16 85:4 85:9 85:16 85:20 87:6 89:15 89:22 90:16 90:16 90:18 91:7 91:12 91:17 91:20 91:23 92:5 92:10 92:11 92:15 92:17 92:22 94:19 95:1 105:8 105:13 106:9 106:10 106:15 107:5 110:3 115:21 119:4 119:7 120:9 120:10 127:12 127:16 128:15 129:17 129:17 129:20 130:16 131:9 135:24

recapture70:24

receive ( 4 ) 23:10 33:15

108:18 129:9 received ( 11 ) 28:25

37:14 49:14 52:14 60:20 61:23 69:7 114:15 127:20 147:25 173:15

receives69:6 receiving ( 2 ) 23:19
60:19

recently, ( 6 ) 3:22 80:24 102:25 147:13 154:6 154:23

reception? ( 3 ) 83:12 90:13 94:21

reckon163:21 reckoner140:18 recognise84:22 recognised107:14 recognition170:15 recollect ( 9 ) 27:7 27:8

27:9 27:10 35:11 43:7 47:13 70:3 144:16

recollection, ( 15 ) 36:5 42:19 42:20 43:8 83:8 83:11 83:21 84:1 89:24 94:14 94:18 127:14 130:14 132:14 146:13

recollections ( 2 ) 27:5 93:6

recommend ( 2 ) 58:8 107:10

recommendation ( 3 )

32:1 39:14 39:22 recommendations ( 2 )
37:21 139:9

recommended ( 4 )

32:6 105:17 106:24 130:16

reconfirm156:6 reconsider8:5 reconvene.178:8 reconvening177:3 record ( 14 ) 38:4 39:23

41:9 48:10 50:24 66:2 71:16 96:23 109:4 117:15 123:10 133:8 144:17 149:4

recorded ( 8 ) 5:21 5:23 30:11 34:3 34:9 45:22 113:7 174:10

records, ( 4 ) 49:6 49:12 52:18 128:25

recover7:17 recovery10:4

refer ( 5 ) 14:8 57:25 62:4 64:10 138:25

reference ( 11 ) 20:14 31:9 45:24 46:11 48:25 49:11 51:13 53:25 134:10 141:8 142:3

references ( 6 ) 13:20 66:23 101:21 156:10 156:17 165:16

referred68:24 referring ( 11 ) 19:23

20:10 24:19 40:1 44:11 45:16 46:3 46:6 129:4 131:2 133:21

refine,154:19 reflect142:13 reflected ( 3 ) 28:5
121:8 139:20

reflection, ( 3 ) 67:20 68:6 176:1

refresh83:11 refusal18:23 refuse12:13

refused ( 5 ) 18:21
65:14 68:25 80:22
resolution ( 3 ) 50:17

35:20 124:19 126:11
81:22 82:1 83:7 83:13
50:25 66:21

127:2
83:18 83:25 84:2 84:4
resolutions50:4

regard ( 29 ) 12:19
84:5 84:10 84:19 85:1
resolve ( 9 ) 2:10 2:13

14:11 32:24 37:15
85:3 90:2 90:4 90:11
3:21 3:25 4:15 4:19

52:18 55:13 58:20
91:9 92:13 92:16
51:25 98:1 98:20

59:16 64:20 67:15
92:19 106:22 147:2
resolved1:7
67:22 69:5 69:25 73:6
remind ( 2 ) 91:3 91:4
resort164:19

90:1 90:3 90:12 92:20
remit, ( 5 ) 43:12 60:3
resource,32:2

93:6 96:15 110:22
60:4 133:17 148:2
respect ( 30 ) 19:24

117:22 118:2 118:4
remote165:19
20:12 23:7 28:6 40:2

118:17 122:13 139:9
removed ( 2 ) 21:5 21:9
43:13 44:9 46:9 50:5

149:11 161:21
render93:5
62:7 64:13 65:21

regards109:25
Renord. ( 2 ) 106:3
67:11 68:13 68:19

regimentation114:8
108:1
68:21 71:12 73:5

registered ( 14 ) 30:10
Renord-Invest? ( 15 ) 94:13 94:15 96:8

31:1 34:3 34:9 60:12
103:16 103:19 104:3
103:20 104:16 106:14

60:12 60:16 61:2
104:7 104:12 104:19
106:23 108:13 133:17

61:8 68:24 69:1 69:4
104:21 105:4 105:7
156:7 156:9 163:17

110:14 159:24
105:10 106:6 106:24
respectful ( 3 ) 97:14

regrettably,149:5
107:16 108:20 108:24
159:6 160:21

regular153:20
repaid. ( 3 ) 8:25 9:21
respective ( 3 ) 30:21

regularly ( 2 ) 35:6
10:1
30:21 126:25

36:12
repay ( 3 ) 10:5 58:2
respectively105:25

regulation,41:5
58:6
respects169:4

regulations. ( 15 ) repayable9:24
respond ( 2 ) 2:15

18:14 19:13 40:4 40:5
repayment ( 3 ) 53:18
124:14

131:13 131:16 138:19
120:5 121:21
response ( 3 ) 74:21

138:23 139:2 139:5
repeat ( 2 ) 8:19 9:5
123:18 155:9

139:8 139:12 139:16
repeated144:22
responsibilities, ( 2 )
139:19 142:13
repeats176:6
58:7 169:22

regulator,16:22
repercussions ( 3 ) responsibility139:11

regulatory137:25
44:24 45:1 45:2
responsible60:21

rehash24:13
replacing32:10
rest ( 4 ) 17:8 50:23

reins101:1
reply,127:20
166:15 178:8

reiterate ( 2 ) 37:16
report, ( 8 ) 39:11 45:25
restructuring ( 4 ) 13:13

120:11
46:10 46:25 47:4 49:2
20:3 20:7 28:1

rejig73:7
87:15 123:21
result ( 8 ) 43:9 44:24

related ( 2 ) 137:9
reports ( 20 ) 41:9 43:19
87:19 105:1 109:20

137:15
44:8 45:11 45:17 46:1
147:15 147:23 173:8

relates110:17
46:6 46:11 46:20 47:8
results ( 2 ) 14:10

relating138:10
47:17 47:22 47:25
108:16

relation ( 2 ) 34:4 50:9
48:6 48:14 48:24
retired119:19

relations136:1
48:25 49:1 49:10
retracted,145:14

relationship.122:14
120:25
return ( 4 ) 6:11 6:13

relatively168:21
reposted61:7
63:5 97:3

release ( 4 ) 144:19
representative172:4
returned, ( 5 ) 26:2 61:7

145:22 148:5 154:7
representatives ( 3 ) 61:9 61:11 62:21

released? ( 5 ) 71:8
110:21 110:25 147:14
revaluation.115:2

96:21 142:24 145:15
repression?45:2
revalue114:20

153:18
request ( 7 ) 35:25
revalued114:21

relevant ( 12 ) 15:1
71:12 75:23 127:8
reveal78:5

20:22 28:17 39:25
173:15 173:25 177:8
reviewed,157:2

52:23 59:11 60:5
require ( 7 ) 2:16 71:17
revise154:14

114:11 134:4 136:25
78:21 78:22 123:25
revised158:1

139:3 140:13
168:15 172:19
revisited176:5

reliance94:6
required ( 4 ) 3:21
right-hand ( 2 ) 54:6

relied ( 7 ) 64:16 94:15
118:21 168:19 169:11
102:16

116:6 118:12 132:16
requirement ( 8 ) 9:11
rightly24:5

132:18 149:8
41:20 58:1 123:25
rights ( 2 ) 7:25 68:15

relief ( 2 ) 15:10 172:16
127:21 128:8 139:20
ring92:9

relies67:12
142:13
rise ( 2 ) 99:2 139:24

reluctantly,164:18
requirements ( 4 ) 9:10
risk ( 2 ) 58:20 59:19

rely ( 7 ) 10:12 101:13
107:3 123:23 138:10
role93:22

115:23 122:7 122:12
requires ( 2 ) 168:10
roles110:7

131:24 132:1
169:18
Rolls172:8

rem8:10
requiring78:6
room. ( 19 ) 83:18 84:2

remainder100:15
reschedule74:3
84:3 84:9 84:11 84:17

remaining76:16
rescheduling72:8
91:10 91:12 91:12

remains ( 2 ) 3:3 122:12
research176:25
91:18 91:22 91:23

remarkable92:7
reserve ( 9 ) 58:12
91:25 94:22 166:20

remarkably119:21
58:15 59:15 76:12
166:20 166:23 167:21

remarks135:7
112:1 112:16 161:17
168:14

remedied.78:13
164:19 171:17
rooms, ( 2 ) 92:2 92:4

remedy29:13
reserves ( 9 ) 58:1 58:5
root155:2

remember, ( 42 ) 4:3
58:8 58:9 58:21 58:22
roped173:10

11:3 12:14 31:4 33:21
58:25 59:20 137:12
roughly, ( 4 ) 58:22 85:6

34:21 36:12 36:17
reserving74:16
85:7 175:17

36:23 44:18 49:25
reside102:10
round ( 5 ) 36:9 49:2

52:10 52:10 52:11
resigned134:20
62:20 100:19 148:25

59:4 61:13 61:17
rounds.21:14

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route.161:23

routine ( 3 ) 17:17 42:8 132:24

RPC171:14

rules. ( 7 ) 12:4 18:14 19:13 101:5 149:13 164:10 168:23

run ( 4 ) 54:11 77:7 164:16 170:14

Russia ( 6 ) 44:20 44:24 71:21 73:9 121:17 138:8

Russian ( 58 ) 18:15 21:20 30:12 33:21 34:10 39:9 42:24 43:3 43:10 45:12 46:21 46:22 47:2 51:4 51:19 51:21 54:24 54:25 55:4 55:12 55:25 56:1 56:6 56:11 56:15 56:19 56:24 57:8 69:11 69:13 87:11 90:24 92:23 109:2 109:12 112:3 113:21 122:18 123:1 130:8 134:13 135:25 138:14 138:19 138:25 139:20 142:9 142:14 151:24 166:13 167:3 167:16 167:17 168:3 168:12 170:10 170:24 170:24

S

safe ( 2 ) 98:16 98:16 safely,33:16 safety110:5

sake ( 3 ) 5:23 117:1 150:9

sale ( 2 ) 10:10 111:9 Sales152:15

same ( 39 ) 1:22 7:7 7:7 20:15 21:7 22:8 22:9 22:12 32:22 56:7 56:12 56:13 59:21 62:22 75:7 85:11 88:2 88:15 91:2 100:17 103:14 110:16 113:21 115:23 116:13 116:16 116:21 116:24 117:2 117:20 117:21 117:22 118:17 120:24 122:18 125:10 127:20 150:25 153:16

sands ( 2 ) 164:14 164:16

satisfactory, ( 2 ) 21:16

115:14

satisfy ( 2 ) 107:3 127:8 Saturday, ( 3 ) 161:5

162:16 163:25 save31:22

Savelyev, ( 8 ) 14:8 14:25 73:5 74:1 75:25 158:10 159:23 162:19

Savelyev’s ( 2 )128:23

129:10

saw ( 10 ) 34:14 34:24 48:4 62:16 62:16 86:2 86:5 86:10 140:5 158:19

saying ( 30 ) 2:9 23:6 24:20 26:16 26:17 28:4 31:4 41:7 44:3 46:2 53:5 60:19 62:13 69:7 82:15 90:24 98:13 104:13 107:8 117:6 120:9 123:8 123:11 125:21 126:4

126:13 129:12 129:14 131:17 134:23

scales59:7

Scan; ( 5 ) 57:1 57:3 65:7 67:13 91:2

Scandinavia ( 9 ) 31:15 55:18 65:16 67:1 111:1 122:24 123:2 137:3 137:14

scenario,98:10 scenarios9:18 schedule, ( 2 ) 33:11
162:5

scheme, ( 2 ) 153:7 168:20

screen ( 20 ) 21:2 21:3 21:5 21:16 22:7 39:6 39:7 40:16 46:4 46:23 53:12 56:2 84:21 103:13 103:14 105:22 106:1 113:19 113:20 125:7

scroll ( 10 ) 46:24 54:15 56:22 56:23 57:7 105:25 115:8 115:9 122:25 130:8

sea89:11

second ( 21 ) 9:22 10:2 10:3 48:24 53:4 56:9 61:16 62:20 63:24 67:7 90:23 90:23 90:24 115:7 117:9 146:18 149:14 158:13 168:7 168:8 169:2

secondly,23:14 secretary30:19 section ( 2 ) 39:13

142:2 sections122:22 secure ( 2 ) 7:13 169:1 secured ( 2 ) 6:16 37:22 securing6:22

security ( 22 ) 6:24 7:1 7:2 7:8 11:6 39:15 40:5 42:13 51:5 51:10 90:13 92:18 92:19 110:9 110:23 123:20 124:10 124:11 126:12 127:3 137:23 137:24

see ( 114 ) 4:23 5:3 5:25 11:13 13:21 16:13 18:1 18:12 18:19 21:16 21:20 21:21 22:5 26:23 37:21 39:6 40:15 45:3 45:24 47:1 47:4 48:18 50:15 50:16 50:17 50:18 50:20 50:21 50:23 50:25 51:2 51:13 51:14 53:2 53:3 53:9 54:16 54:20 54:22 55:2 55:6 55:7 56:3 56:7 56:15 56:19 56:20 56:25 57:2 57:4 57:6 57:8 57:11 57:12 65:11 66:18 66:22 67:5 67:6 69:22 72:3 75:7 75:19 79:7 84:21 90:14 96:25 102:22 105:22 105:23 108:16 109:17 111:13 111:15 112:15 112:23 115:5 117:4 117:10 118:2 119:16 122:23 123:3 123:24 125:7 130:6 133:15 134:8 136:14 137:5 140:23 141:6 142:1 142:6 143:7 143:13 144:4 145:23 158:3 160:15 163:9 164:22 165:20 165:24

171:25 172:1 172:12 172:19 172:25 173:9 174:12 175:13 176:25 177:18

seek ( 2 ) 138:8 178:4 seem ( 4 ) 51:9 133:4

145:8 163:17 seemingly, ( 2 ) 56:16
152:11

seems ( 15 ) 17:23 17:24 53:2 55:5 71:4 97:20 98:24 136:7 144:14 145:9 148:4 157:9 161:20 162:22 165:2

seen ( 4 ) 2:17 9:3 57:13 99:20

segments?38:11 select ( 2 ) 167:8 167:19 selected170:3 selecting ( 2 ) 167:6

167:7 sell11:11 selling10:6

send ( 12 ) 30:22 33:8 33:17 34:24 34:25 35:19 37:16 52:6 60:16 61:19 69:1 157:18

sender.69:9 sending ( 10 ) 30:20

32:19 33:14 48:2 60:1 60:14 60:22 62:10 125:1 126:25

sends33:8

senior ( 2 ) 159:24 161:9

sense ( 5 ) 70:18 108:23 149:8 169:2 169:9 sensible ( 6 ) 97:6 98:18 120:7 121:24 144:8
157:7 sensibly100:2

sent ( 28 ) 1:22 16:14 30:9 30:10 30:16 31:1 31:2 31:10 31:22 31:24 33:2 34:9 34:15 34:18 35:2 55:7 57:14 60:11 60:12 61:2 61:14 61:25 62:3 62:22 63:4 63:8 81:22 89:18

separate ( 4 ) 40:7 138:13 139:7 159:17

separately,32:18 sequence ( 4 ) 11:13
14:23 49:9 84:16

SERGEYEVNA ( 2 ) 6:7

179:4

series ( 4 ) 26:19 30:8 51:9 127:18

serious ( 2 ) 64:3 99:1 seriously ( 3 ) 32:11
77:10 133:5

served ( 2 ) 155:16

155:17 server32:3

services ( 8 ) 104:11 104:15 104:15 105:10 106:3 106:5 106:13 106:19

session. ( 2 ) 171:9 171:10

set ( 12 ) 1:12 8:6 43:22 54:19 59:19 103:5 118:20 131:23 135:11 157:14 166:20 175:18

sets ( 3 ) 41:18 50:22 72:9

setting58:4 settle171:9

seven9:8
98:17 102:16 106:17
Slavovna ( 2 ) 43:5
83:5 83:6 167:9
99:19 102:2 102:13
113:16 126:16 128:2

several ( 7 ) 33:12 61:24
152:2 177:11
135:22
167:10 168:4
102:14 102:19 102:20
129:3 130:6 130:8

62:3 85:10 85:11
sight173:2
sleepy,172:2
(Speaks151:24
102:24 103:1 103:6
132:15 132:21 133:1

106:25 119:9
sign ( 23 ) 18:21 18:23
slicing175:16
special. ( 2 ) 92:16
107:22 107:24 107:25
133:22 134:6 134:10

Shabalina ( 55 ) 72:16
23:8 24:8 25:25 33:3
slight, ( 2 ) 60:8 174:4
92:16
118:25 119:17 122:17
134:16 135:1 135:14

72:20 72:21 73:2 75:9
41:12 60:19 64:5
slightly ( 8 ) 58:17
specialised87:22
127:9 127:16 127:25
135:15 135:17 135:22

75:15 75:16 75:18
67:22 67:25 69:7
75:12 90:7 115:8
specialist ( 2 ) 69:5
128:3 130:15 130:18
136:10 136:14 136:17

76:12 76:17 76:20
83:12 85:18 86:2
117:24 152:1 168:22
110:24
131:2 131:15 132:2
141:10 142:23 142:25

76:24 77:15 97:9 98:6
86:10 86:25 90:15
175:16
specific ( 14 ) 11:13
134:2 136:23 138:5
143:2 143:14 143:17

99:17 99:23 100:4
130:21 131:9 132:8
slipped ( 2 ) 96:24
19:23 20:2 34:25
150:21 150:23 151:9
143:20 144:5 144:22

100:12 100:25 101:11
150:19 167:21
177:24
42:19 44:22 63:18
154:16 155:25 156:3
147:5 147:9 148:10

102:1 102:4 102:8
sign-off.17:22
slips.33:24
78:12 82:21 104:14
156:13 178:6
149:2 149:9 150:12

102:10 102:12 102:14
signalled112:13
slot. ( 3 ) 72:22 82:22
118:15 122:13 126:16
statements, ( 3 ) 13:25
151:6 151:16 151:24

103:7 103:10 103:11
signatory.139:11
162:2
129:3
71:17 130:1
152:20 154:18 155:12

103:13 103:15 109:17
signature ( 26 ) 18:6
slow ( 2 ) 32:3 161:6
specifically ( 2 ) 13:16
states10:8
156:4 157:5 157:7

111:11 112:22 113:23
21:18 21:20 21:21
slowly.120:16
16:17
stating ( 3 ) 24:9 53:23
157:10 157:16 157:25

115:11 117:6 119:1
22:1 22:10 22:11
small ( 11 ) 62:25 64:5
specified, ( 3 ) 9:25
58:11
158:8 159:4 159:22

119:15 119:19 120:4
22:13 22:13 23:4 23:5
64:6 83:6 88:19 89:13
114:18 114:19
status» ( 2 ) 21:4 137:13
160:5 161:1 162:7

121:20 125:6 125:17
24:9 26:2 29:11 42:1
91:11 91:12 91:13
specify ( 3 ) 13:16 86:1
stay97:18
162:9 162:21 163:1

127:9 128:20 130:20
80:21 86:6 88:4 94:6
91:13 123:22
131:1
Steadman, ( 3 ) 145:4
163:19 163:22 164:1

131:14 132:7 134:18
94:8 102:22 102:23
Smirnov ( 2 ) 108:5
speculate. ( 2 ) 36:22
176:14 176:16
164:4 164:5 164:18

135:22 136:6 136:22
109:18 112:23 132:13
108:14
115:24
step ( 2 ) 125:11 126:3
165:8 166:1 166:2

179:21
139:18
so-called ( 2 ) 15:24
speed131:5
steps ( 4 ) 3:18 4:23
166:9 169:12 170:19

Shabalina’s ( 2 )120:1signatures ( 5 ) 26:3
27:24
spend100:3
91:21 144:19
171:14 171:17 174:19

121:11
88:6 88:7 88:8 88:10
Société ( 2 ) 99:9
spending153:10
still ( 14 ) 30:1 36:7
174:23 175:2 175:6

shall ( 16 ) 9:5 15:21
signed ( 21 ) 19:25 23:2
145:10
spent,164:9
47:16 47:23 79:19
176:1 177:14 177:18

21:8 41:4 51:5 70:21
25:1 27:21 29:5 35:14
sofa ( 12 ) 83:14 84:2
spill73:10
98:17 110:15 112:6
178:2 178:7 178:11

76:7 78:7 78:21
41:22 48:5 86:23 87:3
84:3 91:7 91:8 91:14
spilling73:15
116:6 122:8 150:5
179:6 179:10 179:15

100:11 120:10 143:11
88:10 88:24 91:24
91:20 91:22 92:6 92:8
split38:11
151:4 152:20 172:10
179:17 179:23

148:25 150:23 156:2
92:1 92:14 111:12
94:23 95:14
spoke ( 2 ) 31:3 31:3
stock161:15
Stroilov’s ( 4 )72:7 73:5

176:12
111:15 112:19 114:1
software,16:25
spousal ( 12 ) 25:15
stocks.153:19
150:10 159:7

shapes93:25
131:7 131:12
sold,11:1
25:20 26:1 27:18
stood ( 4 ) 74:12 161:18
strongly ( 5 ) 25:15

share5:18
significance93:13
solely7:9
132:9 138:8 138:11
165:7 176:21
26:22 28:3 41:15

shared74:20
significant97:25
solicitors ( 4 ) 1:22 4:11
138:15 138:17 139:4
stop ( 2 ) 72:25 133:1
149:19

sharply ( 2 ) 120:2
signified120:24
109:7 125:14
140:13 141:6
stopped3:5
structurers107:17

121:12
signifies ( 2 ) 114:14
solution ( 3 ) 35:24
spouse ( 3 ) 138:12
stopping40:20
subject ( 13 ) 6:12 7:20

sheet ( 2 ) 111:8 140:23
116:7
120:8 121:24
138:21 139:6
story93:3
32:15 35:21 37:1 37:1

Shevelev111:16
signify64:15
somebody.173:16
spouse’s61:22
straight.135:21
41:23 59:15 96:23

Shipping ( 5 ) 39:12
signing ( 11 ) 20:13
somehow ( 5 ) 3:22
spring,36:23
straightaway33:1
110:10 151:5 165:3

50:21 53:19 55:16
23:1 24:23 80:22
21:5 34:20 71:6
square46:14
Street ( 6 ) 34:16 34:20
169:8

108:18
83:13 85:24 86:4 86:5
144:18
staff172:8
62:1 62:1 62:17
submit25:14

short ( 15 ) 13:23 39:3
86:8 89:3 139:10
someone ( 11 ) 22:3
stage. ( 5 ) 6:18 12:10
102:11
subparagraph?51:15

55:9 72:13 72:14
«silent»,88:24
36:13 37:4 42:18 69:6
68:15 128:22 148:14
stress ( 3 ) 4:9 5:4 5:5
subparagraphs,51:9

75:21 78:2 89:6
silly48:22
83:24 89:18 96:25
Stalevskaya ( 3 ) 73:23
stretches,156:21
subsequent ( 3 ) 74:14

101:15 124:11 124:22
similar ( 6 ) 40:9 88:6
124:17 152:2 158:16
162:1 163:19
strict ( 2 ) 23:16 114:7
133:9 163:17

124:23 142:2 143:7
88:11 116:12 116:18
something ( 33 ) 2:2
stand? ( 3 ) 24:1 74:1
strictly ( 3 ) 22:16 23:3
subsequently ( 4 ) 10:9

144:1
120:13
21:4 22:17 23:3 24:16
144:20
58:10
33:14 94:7 94:16

shorter ( 2 ) 75:6 76:24
simple134:5
24:20 26:21 29:12
standard ( 6 ) 9:5 10:22
STROILOV: ( 200 ) 1:5 subsidiaries,104:22

should ( 57 ) 1:18 2:12
simultaneously ( 3 ) 29:17 30:24 31:12
28:9 34:15 116:1
1:12 1:25 2:14 2:23
substance, ( 4 ) 4:19

7:19 28:19 29:24 32:8
7:25 11:5 11:25
31:24 32:12 33:20
153:20
3:2 4:13 5:3 5:11 5:25
14:21 101:13 101:14

33:1 44:13 54:4 61:1
Since ( 5 ) 122:1 148:5
34:21 35:11 37:18
standards137:8
6:10 6:11 8:2 8:11
substantive26:9

62:17 64:25 65:1
151:8 166:3 166:4
41:17 49:1 49:7 49:23
standby165:7
8:20 8:22 11:8 12:24
substitute70:18

65:13 70:10 71:17
single ( 4 ) 28:6 86:7
64:5 92:22 97:23
standing159:23
13:2 13:5 16:5 21:10
substituted18:8

77:4 78:3 88:24 89:3
128:17 133:16
112:14 123:24 125:22
stands149:5
21:15 25:4 25:14
suddenly153:22

89:14 110:10 120:16
sir ( 13 ) 9:11 13:16
133:23 155:4 168:18
stapled?85:15
26:14 26:17 26:21
sufficient ( 5 ) 10:4 88:8

123:9 126:2 126:14
18:11 34:17 35:11
170:21 171:9 171:14
start ( 13 ) 36:10 42:9
26:23 27:13 27:19
147:10 148:21 150:18

128:24 128:24 129:1
37:15 38:10 38:10
sometimes ( 9 ) 14:18
76:7 76:11 79:9 98:18
28:3 30:4 30:7 38:18
suggest ( 16 ) 8:12

130:1 132:25 133:22
93:8 95:19 117:13
18:7 23:8 31:3 63:3
100:4 100:11 125:25
38:21 39:5 41:14 45:4
19:17 24:5 25:5 25:15

134:12 139:6 139:13
131:2 133:21
98:7 124:8 124:10
159:13 159:14 175:12
45:9 45:17 46:7 48:8
27:24 29:10 29:22

140:12 145:14 146:8 sit ( 6 ) 80:2 94:23 100:6
125:1
175:18
49:7 49:18 52:6 54:8
79:20 113:10 137:2

147:1 150:1 151:6
112:16 128:18 168:13
somewhat6:20
started ( 6 ) 14:12 23:24
54:10 66:16 67:19
145:9 151:5 160:2

152:6 155:6 155:25
site ( 6 ) 110:9 110:14
somewhere ( 2 ) 71:20
36:9 53:17 62:14
68:2 68:5 68:11 68:22
162:1 175:11

156:16 157:19 158:6
110:14 115:14 117:20
172:12
82:25
68:23 69:15 70:12
suggested ( 13 ) 20:5

161:7 163:11 163:12
165:21
soon. ( 5 ) 6:6 24:2
starting66:8
70:21 72:19 73:1
28:18 35:22 40:8

164:9 165:6 169:1
sits173:8
63:21 108:3 140:8
stated, ( 8 ) 8:17 37:10
73:11 73:16 74:6
40:10 47:7 49:19 52:9

169:19 170:6 170:9
sitting ( 7 ) 73:19 83:13
sooner. ( 3 ) 4:22 38:22
55:6 61:20 61:22
74:23 75:2 75:11
76:10 96:14 105:9

175:21
84:2 91:14 95:1 95:14
140:12
116:4 120:13 147:12
75:17 75:20 76:11
128:9 151:17

shouldn’t ( 3 )126:7
167:21
sort ( 9 ) 49:23 56:25
statement, ( 80 ) 5:22
76:14 76:20 76:23
suggesting ( 11 ) 9:13

163:3 174:5
situation. ( 10 ) 63:13
66:13 78:11 91:15
5:23 8:6 8:18 8:23 9:4
77:6 77:9 77:25 78:15
9:15 38:3 39:20 105:8

show ( 11 ) 50:3 52:17
121:9 123:20 129:21
106:16 112:1 146:2
13:19 24:12 24:15
78:18 78:25 79:3
113:8 113:12 124:16

54:4 54:5 65:10 65:25
133:20 148:14 150:6
150:16
24:25 25:9 25:10
81:8 81:9 88:15 88:16
126:18 129:5 130:20

66:1 66:7 109:1 140:2
150:24 152:21 155:22
sorted?166:14
25:12 26:12 26:19
88:21 89:8 93:9 95:7
suggestion ( 7 ) 72:11

172:2
situations11:10
sorts ( 2 ) 169:4 169:7
27:1 27:4 27:11 27:14
95:11 95:12 95:22
115:22 116:21 144:5

showed49:7
six ( 3 ) 75:4 96:5
sought ( 3 ) 105:15
27:23 31:13 31:21
97:17 98:7 98:10
151:7 165:2 173:1

shown ( 9 ) 16:21 45:8
125:17
124:12 139:5
44:2 44:7 44:12 45:15
98:16 98:23 99:3
suggestions,37:21

50:3 50:6 55:24 80:9
six-and166:25
sounds ( 6 ) 71:3 77:14
46:4 46:12 46:21
99:12 99:13 99:15
suggests ( 4 ) 106:4

80:11 102:12 130:1
size ( 2 ) 90:1 91:10
128:5 131:14 157:7
47:10 49:5 57:23
100:24 101:3 101:8
115:18 117:7 123:8

shows ( 3 ) 54:6 141:5
sky-high108:8
175:25
59:24 62:5 63:1 64:9
101:16 101:20 103:8
suit ( 2 ) 25:24 26:7

152:10
skyscraper83:5
source ( 2 ) 45:2 45:3
64:19 67:21 67:25
103:9 103:10 105:8
suits?175:21

side ( 11 ) 12:19 12:20
slammed158:16
speaking ( 9 ) 12:11
78:21 80:10 80:15
109:17 112:6 112:9
sum ( 2 ) 6:23 7:22

54:6 69:25 70:1 98:16
22:16 24:22 44:10
80:23 81:5 84:15
112:22 113:1 113:8
summarised25:23

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summer? ( 2 ) 36:18
tall89:12
third ( 4 ) 51:15 66:23
75:15 76:17 78:6 81:1

36:19
tallest89:13
104:22 104:23
96:20 97:23 98:20

sums15:25
tampering47:8
though ( 7 ) 22:12 22:16
99:2 100:6 100:24

Sunday, ( 4 ) 14:2 161:5
task ( 2 ) 31:22 130:10
44:14 47:15 100:9
103:2 128:18 131:14

162:16 163:25
tax153:7
108:18 178:7
142:10 144:23 151:1

supervised ( 2 ) 17:19
team,108:14
thought ( 17 ) 18:22
153:23

18:14
technical ( 2 ) 135:4
32:12 47:20 71:6
today’s144:16

supervisor,17:20
166:18
72:4 75:5 75:6 76:12
together, ( 3 ) 36:11

supplemented ( 3 ) technically?21:16
106:16 111:22 120:4
62:22 103:19

64:17 64:25 65:1
technique87:24
121:20 145:17 145:25
told, ( 28 ) 14:19 15:6

supplied? ( 2 ) 139:13
techniques.87:23
172:22 173:6 173:9
20:21 22:19 23:14

141:10
technology172:4
thoughts163:16
24:17 25:10 26:8

suppose ( 3 ) 119:3
telephone ( 3 ) 23:25
thousand126:5
26:18 27:2 35:7 37:12

134:7 139:22
119:18 168:8
three ( 13 ) 35:1 62:21
44:17 49:11 67:22

Supreme164:13
telling ( 2 ) 25:6 137:1
74:5 99:11 104:7
71:1 76:23 89:10

sure ( 42 ) 10:23 14:22
tells1:25 109:9 148:18 148:23
142:19 146:5 150:25

14:23 19:21 22:2 24:1
ten145:7
158:10 161:22 167:20
154:4 154:25 166:23

24:20 26:11 36:17
tends98:3
167:22 167:25
169:5 169:10 170:24

54:10 54:11 55:10
tenure.104:8
through ( 14 ) 10:16
177:23

68:14 69:2 70:14
term ( 8 ) 6:13 9:24 41:3
38:6 74:4 75:17 85:18
tolerably70:3

83:17 84:23 86:5 89:2
59:6 69:10 107:11
86:12 95:2 95:17
tomorrow, ( 22 ) 73:2

89:25 94:11 96:11
128:11 128:14
101:17 126:7 146:8
76:13 77:4 77:10

100:22 103:25 105:12
Terminal, ( 3 ) 110:17
151:7 167:14 173:20
97:19 99:24 99:25

108:13 113:13 124:22
111:13 165:17
throughout ( 2 ) 36:6
144:10 151:7 151:11

125:15 126:15 126:17
terminology. ( 2 ) 30:13
104:8
151:19 154:20 160:15

132:10 133:14 133:19
69:12
Thursday, ( 10 ) 73:15
161:3 162:16 171:20

134:1 136:19 142:20
terms ( 23 ) 15:1 25:13
73:18 77:6 77:7
173:11 176:15 177:4

152:17 161:1 170:19
32:10 34:10 40:18
158:24 159:15 160:4
177:10 177:20 178:5

172:6 173:4
41:2 41:19 68:16 72:4
160:6 161:4 178:15
tongue.141:9

surely137:20
74:11 74:17 107:3
thus,114:19
tonight.144:13

surety141:24
107:6 124:8 124:9
tick49:23
too ( 17 ) 2:11 23:16

suretyship ( 2 ) 9:6
127:6 133:2 134:4
tidied177:7
25:19 36:11 45:5

20:10
145:17 147:18 156:24
tie155:6
66:13 76:6 78:1 90:10

surmise ( 2 ) 36:22 87:7
168:1 174:22
time, ( 108 ) 4:14 5:14
106:7 106:8 130:9

surmised,137:15
terrible147:18
8:3 8:24 9:16 9:19
138:3 143:22 146:7

surprise,140:20
terribly129:5
10:21 10:25 11:12
148:8 169:4

surprised ( 4 ) 48:16
territory169:3
13:2 13:23 19:15
took ( 3 ) 18:3 66:19

48:16 85:4 157:24
test.178:10
19:19 19:22 19:24
66:22

surprises71:16
text99:20
20:13 20:20 23:17
tool174:2

surrounding105:13
That’s ( 63 )6:3 10:15
27:6 28:1 28:10 30:18
total ( 2 ) 137:10 137:19

survive ( 2 ) 31:19
13:4 14:16 14:16
32:11 32:22 33:2
totally ( 4 ) 40:7 41:15

154:11
22:4 25:10 26:9 26:20
33:3 33:13 34:12
105:6 106:12

survived31:6
39:10 41:2 44:17 45:4
35:13 36:20 40:23
touch129:24

suspect157:10
49:15 51:10 54:10
42:22 47:25 58:24
touched6:12

suspicions.12:17
57:4 63:7 68:11 70:14
61:10 62:20 65:21
tough,164:16

suvedomleniyem; ( 3 ) 80:15 86:8 86:18
72:3 73:6 74:7 74:11
towards ( 2 ) 66:14

30:14 34:3 34:11
88:14 91:17 94:12
74:17 74:24 75:24
115:16

swiftly.143:8
94:18 95:2 95:5 95:20
76:9 76:16 77:19 79:1
track ( 4 ) 33:10 60:4

swore53:1
98:20 112:9 112:24
79:13 81:25 82:5 82:9
100:19 141:1

sworn ( 3 ) 53:3 53:7
113:1 113:8 113:15
82:14 82:18 82:19
tracked173:16

53:9
113:21 113:23 114:2
82:21 82:25 84:4 85:7
tracks165:23

sympathy. ( 2 ) 162:12
116:25 118:3 119:15
87:20 88:13 90:10
tradition,175:20

164:6
123:7 126:13 130:9
93:23 95:20 98:14
tranches14:5

system ( 10 ) 15:1 15:23
134:6 134:22 136:19
100:3 103:24 104:1
transact ( 2 ) 100:7

16:4 17:4 58:19 58:19
143:20 145:23 147:3
111:21 112:11 112:13
146:7

141:14 173:18 173:20
147:14 152:1 152:15
116:2 117:11 117:12
transacted.82:21

174:11
154:6 154:9 154:11
118:23 120:10 124:13
transcript, ( 10 ) 39:8

155:20 164:16 165:10
124:15 127:19 127:20
69:17 70:11 88:23

T 168:20 169:9 175:7
127:22 128:10 128:12
101:23 109:15 143:7

themselves.170:23
128:14 129:4 129:12
154:15 169:14 173:20

there’s167:5
132:18 138:3 139:3
transcripts152:4

tab, ( 4 ) 22:8 116:16

thereafter29:14
140:1 141:6 143:8
transfer153:14

117:3 122:18
thereby,163:14
144:5 146:14 146:18
transferring ( 2 ) 130:23

table99:11
Therefore ( 14 ) 3:20
149:19 151:12 158:8
153:9

tables34:7
5:20 14:3 28:14
159:9 159:10 161:1
translate ( 4 ) 30:11

tabs,66:13
78:3 78:12 88:1 93:7
161:2 162:4 164:9
53:5 87:13 110:20

taken ( 6 ) 47:20 74:12
111:24 124:1 137:16
166:2 168:6 170:9
translated ( 5 ) 22:10

83:22 142:15 159:12
150:1 160:23 177:25
178:9
51:16 101:12 119:1

168:5
thereto.93:7
times ( 5 ) 33:12 62:3
141:13

takes ( 5 ) 11:11 11:12
thin ( 2 ) 94:14 94:18
121:18 134:24 175:8
translation ( 10 ) 51:3

13:2 78:25 153:16
thing, ( 21 ) 9:20 14:25
timetable ( 12 ) 73:7
51:15 51:19 55:1

taking ( 10 ) 1:19 5:6
15:13 16:3 16:5 16:6
74:14 74:18 79:20
55:10 69:20 109:16

35:20 59:13 115:13
21:17 40:6 47:21 64:6
97:13 144:7 148:24
112:5 112:14 113:22

129:20 140:6 144:18
77:22 78:5 79:3 89:15
157:17 157:19 158:1
translations157:22

148:16 154:21
90:14 113:12 134:23
158:12 163:3
translator,71:1

talk118:1
135:2 146:1 155:10
timetabling, ( 4 ) 72:4
translators ( 6 ) 52:23

talking ( 12 ) 9:15 20:7
170:6
144:9 157:22 161:3
70:7 70:22 87:13

23:23 24:24 37:4
thinking ( 2 ) 130:25
tip164:14
109:13 110:20

59:18 65:14 65:16
176:23
today. ( 24 ) 49:16
transport115:14

110:13 120:12 167:17
thinks ( 2 ) 143:6 170:3
55:19 59:25 69:17
trapped160:13

172:7
69:19 72:24 72:25
travel?96:10

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travelled81:12 travelling ( 2 ) 89:21

90:8 trespass101:2

trial ( 7 ) 2:3 71:15 74:5 112:3 141:17 158:1 161:3

tried ( 8 ) 47:12 47:13 47:21 107:16 128:12 131:20 141:1 144:7

tripartite ( 4 ) 39:18 40:2 65:19 67:15

trips141:8

trouble ( 2 ) 38:6 175:22 troubled98:22

true, ( 14 ) 23:3 26:4 53:9 81:2 81:6 89:10 94:18 103:3 103:6 106:10 112:9 123:7 149:6 153:2

trust ( 2 ) 67:4 107:17 truth, ( 4 ) 25:6 67:23

93:14 120:23 truthfulness,44:17

try ( 18 ) 3:19 3:25 4:19 5:19 15:16 36:1 48:12 48:18 70:21 75:13 83:11 84:5 99:16 146:8 152:3 154:19 162:2 172:12

trying ( 16 ) 12:5 23:18 24:6 26:14 28:8 35:23 46:5 46:8 57:24 73:7 122:8 122:10 127:24 134:22 140:8 176:19

tube.175:23

Tuesday, ( 7 ) 73:11 159:7 159:9 159:11 159:12 160:4 160:5

turn ( 6 ) 80:19 80:20 84:21 86:10 102:21 129:2

turned ( 2 ) 54:3 74:15 turning ( 2 ) 32:16 86:12 two-thirds21:9 type91:17

types ( 4 ) 7:21 11:5 11:6 89:16

typo ( 2 ) 63:25 64:4 typographical62:6 typos ( 2 ) 29:16 64:3

U

Ugolnaya111:2 unable84:8 unavailable170:25 unclear147:25 uncomfortable149:15 uncommercial.108:4 unconnected ( 2 ) 105:3
105:4 uncontrolled175:5 understand ( 46 ) 2:23

3:7 6:15 7:11 10:16 13:8 13:22 14:23 16:6 16:16 16:20 17:14 19:21 22:15 22:24 23:2 23:12 24:21 25:18 31:6 32:16 37:2 38:9 47:23 55:7 64:9 70:2 77:1 101:24 104:2 114:4 116:10 125:6 133:14 134:23 136:25 144:11 150:1 151:2 151:4 158:5 168:9 169:22 170:20 170:21 172:3

understandable,144:6

understanding ( 16 )

3:2 15:9 46:7 49:15 104:4 111:11 142:12 147:11 147:20 148:13 153:5 162:24 164:24 170:22 171:2 173:23

understandings14:12 understands, ( 2 )

66:12 109:4 understood ( 7 ) 5:8

9:10 28:23 96:11 112:24 126:15 144:21

undertaken100:16 undoubted ( 2 ) 12:20

70:1 unduly,8:3

unequivocally138:3 unfair,163:18 unfolding129:21 unfortunate,149:7

Unfortunately ( 7 )

16:11 22:6 69:9 74:10 83:21 90:4 91:4

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unlikely; ( 3 ) 9:3 10:18 169:21

unnecessary,2:21 unobjectionable.157:20 unredacted177:9 unrelated105:6 unreliable,26:20 unsatisfactory ( 2 )

112:12 127:4 untested.169:3 unthinkable11:19 untrue, ( 2 ) 22:17 27:15 unusual,2:20 unwilling168:18 uploaded ( 4 ) 140:2

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valuations ( 3 ) 114:13 115:3 118:16

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